Motivated by the fact that geomagnetic field inhomogeneity is weak close to the chorus generation region and the observational evidence that falling-tone chorus tend to have large oblique angles of propagation, we propose that falling-tone chorus start as a marginally unstable mode. The marginally unstable mode requires the presence of a relatively large damping, which has its origins in the Landau damping of oblique waves in this collisionless environment. A marginally unstable mode produces phase-space structures that release energy and produce wave chirping. We show that the present model produces results in reasonable agreement with observations.