the effort was “subtle or circuitous” and “however cleverly or with whatever cloaking of purpose” it was made. United States v. Roe, 529 F.2d 629, 632 (4th Cir. 1975); see also United States v. Quattrone, 441 F.3d 153, 173 (2d Cir. 2006). The verbs ‘“obstruct or impede’ are broad” and “can refer to anything that blocks, makes difficult, or hinders.” Marinello v. United States, 138 S. Ct. 1101, 1106 (2018) (internal brackets and quotation marks omitted). An improper motive can render an actor’s conduct criminal even when the conduct would otherwise be lawful and within the actor’s authority. See United States v. Cueto, 151 F.3d 620, 631 (7th Cir. 1998) (affirming obstruction conviction of a criminal defense attorney for “litigation-related conduct”); United States v. Cintolo, 818 F.2d 980, 992 (1st Cir. 1987) (“any act by any party —whether lawful or unlawful on its face—may abridge § 1503 if performed with a corrupt motive”). Nexus to a pending or contemplated official proceeding. Obstruction-of- justice law generally requires a nexus, or connection, to an official proceeding. In Section 1503, the nexus must be to pending “judicial or grand jury proceedings.” United States v. Aguilar, 515 U.S. 593, 599 (1995). In Section 1505, the nexus can include a connection to a “pending” federal agency proceeding or a congressional inquiry or investigation. Under both statutes, the government must demonstrate “a relationship in time, causation, or logic” between the obstructive act and the proceeding or inquiry to be obstructed. Id. at 599; see also Arthur Andersen LLP v. United States, 544 U.S. 696, 707-708 (2005). Section 1512(c) prohibits obstructive efforts aimed at official proceedings including judicial or grand jury proceedings. 18 U.S.C. § 1515(a)(1) (A). “For purposes of” Section 1512, “an official proceeding need not be pending or about to be instituted at the time of the offense.” 18 U.S.C. § 1512(f) (1). Although a proceeding need not already be in progress to trigger liability under Section 1512(c), a nexus to a contemplated proceeding still must be shown. United States v. Young, 916 F.3d 368, 386 (4th Cir. 2019); United States v. Petruk, 781 F.3d 438, 445 (8th Cir. 2015); United States v. Phillips, 583 F.3d 1261, 1264 (10th Cir. 2009); United States v. Reich, 479 F.3d 179, 186 (2d Cir. 2007). The nexus requirement narrows the scope of obstruction statutes to ensure that individuals have “fair warning” of what the law proscribes. Aguilar, 515 U.S. at 600 (internal quotation marks omitted). The nexus showing has subjective and objective components. As an

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