26, 2007), at pp. 15-28; United States v. Singleton, Nos. H-04-CR-514SS, H-06-cr-80 (S.D. Tex. filed June 5, 2006). 1078 The Office of Legal Counsel recently relied on several of the same interpretive principles in concluding that language that appeared in the first clause of the Wire Act, 18 U.S.C. § 1084, restricting its prohibition against certain betting or wagering activities to “any sporting event or contest,” did not apply to the second clause of the same statute, which reaches other betting or wagering activities. See Reconsidering Whether the Wire Act Applies to Non-Sports Gambling (Nov. 2, 2018), slip op. 7 (relying on plain language); id. at 11 (finding it not “tenable to read into the second clause the qualifier ‘on any sporting event or contest’ that appears in the first clause”); id. at 12 (relying on Digital Realty). 1079 In Sykes v. United States, 564 U.S. 1, 15 (2011 ), the Supreme Court substantially abandoned Begay’s reading of the residual clause, and in Johnson v. United States, 135 S. Ct. 2551 (2015), the Court invalidated the residual clause as unconstitutionally vague. Begay’s analysis of the word “otherwise” is thus of limited value. 1080 The Supreme Court’s decision in Marinello v. United States, 138 S. Ct. 1101 (2018), does not support imposing a non-textual limitation on Section 1512(c)(2). Marinello interpreted the tax obstruction statute, 26 U.S.C. § 7212(a), to require “a ‘nexus’ between the defendant’s conduct and a particular administrative proceeding.” Id. at 1109. The Court adopted that construction in light of the similar interpretation given to “other obstruction provisions,” id. (citing Aguilar and Arthur Andersen), as well as considerations of context, legislative history, structure of the criminal tax laws, fair warning, and lenity. Id. at 1106-1108. The type of “nexus” element the Court adopted in Marinello already applies under Section 1512(c)(2), and the remaining considerations the Court cited do not justify reading into Section 1512(c)(2) language that is not there. See Bates v. United States, 522 U.S. 23, 29 (1997) (the Court “ordinarily resist[s] reading words or elements into a statute that do not appear on its face.”). 1081 The Senate ultimately accepted the House version of the bill, which excluded an omnibus clause. See United States v. Poindexter, 951 F.2d 369, 382-383 (D.C. Cir. 1991) (tracing history of the proposed omnibus provision in the witness-protection legislation). During the floor debate on the bill, Senator Heinz, one of the initiators and primary backers of the legislation, explained that the omnibus clause was beyond the scope of the witness-protection measure at issue and likely “duplicative” of other obstruction laws, 128 Cong. Rec. 26,810 (1982) (Sen. Heinz), presumably referring to Sections 1503 and 1505. 1082 In a separate section addressing considerations unique to the presidency, we consider principles of statutory construction relevant in that context. See Volume II, Section III.B.l, infra. 1083 In United States v. Poindexter, 951 F.2d 369 (D.C. Cir. 1991), the court of appeals found the term “corruptly” in 18 U.S.C. § 1505 vague as applied to a person who provided false information to Congress. After suggesting that the word “corruptly” was vague on its face, 951 F.2d at 378, the court concluded that the statute did not clearly apply to corrupt conduct by the person himself and the “core” conduct to which Section 1505 could constitutionally be applied was one person influencing another person to violate a legal duty. Id. at 379-386. Congress later enacted a provision overturning that result by providing that “[a]s used in [S]ection 1505, the term ‘corruptly’ means acting with an improper purpose, personally or by influencing another, including by making a false or misleading statement, or withholding, concealing, altering, or destroying a document or other information.” 18 U.S.C. § 1515(b). Other courts have declined to follow Poindexter either by limiting it to Section 1505 and the specific conduct at issue in that case, see Brenson, 104 F.3d at 1280-1281; reading it as narrowly limited to certain types of conduct, see United States v. Morrison, 98 F.3d 619, 629-630 (D.C. Cir. 1996); or by noting that it predated Arthur Andersen’s interpretation of the term “corruptly,” see Edwards, 869 F.3d at 501-502.