In US v. Tara Mezzeo, (9th Cir. 2015) No. 13-10481 D.C. No. 2:12-cr-00337-JCM-CWH-1 a citizen supposedly lied to government agents relating to an 18 U.S.C. §1035 (healthcare) matter and were prosecuted under 18 U.S.C. §1001.  Agent notes were not admitted into evidence and their proffer was considered weak on appeal.  The "knowledge of illegality / knowledge of falsity" element was not objected to at trial. The conviction was upheld.  This result emphasizes that ANYTHING that a citizen says to law enforcement can be MISCONSTRUED, and this is why the right to remain silent is both important and necessary.  If the citizen in this case had remained silent, the prosecution and conviction would likely not have occurred.