2. Judicial Decisions Support a Broad Reading of Section 1512(c)(2) Courts have not limited Section 1512(c)(2) to conduct that impairs evidence, but instead have read it to cover obstructive acts in any form. As one court explained, “[t]his expansive subsection operates as a catch-all to cover ‘otherwise’ obstructive behavior that might not constitute a more specific offense like document destruction, which is listed in (c)(l).” United States v. Volpendesto, 746 F.3d 273, 286 (7th Cir. 2014) (some quotation marks omitted). For example, in United States v. Ring, 628 F. Supp. 2d 195 (D.D.C. 2009), the court rejected the argument that “§ 1512(c)(2)’s reference to conduct that ‘otherwise obstructs, influences, or impedes any official proceeding’ is limited to conduct that is similar to the type of conduct proscribed by subsection (c)(l)—namely, conduct that impairs the integrity or availability of ‘record[s], documents[s], or other object[s] for use in an official proceeding.” Id. at 224. The court explained that “the meaning of § 1512(c)(2) is plain on its face.” Id. (alternations in original). And courts have upheld convictions under Section 1512(c)(2) that did not involve evidence impairment, but instead resulted from conduct that more broadly thwarted arrests or investigations. See, e.g., United States v. Martinez, 862 F.3d 223, 238 (2d Cir. 2017) (police officer tipped off suspects about issuance of arrest warrants before “outstanding warrants could be executed, thereby potentially interfering with an ongoing grand jury proceeding”); United States v. Ahrensfield, 698 F.3d 1310, 1324-1326 (10th Cir. 2012) (officer disclosed existence of an undercover investigation to its target); United States v. Phillips, 583 F.3d 1261, 1265 (10th Cir. 2009) (defendant disclosed identity of an undercover officer thus preventing him from making controlled purchases from methamphetamine dealers). Those cases illustrate, that Section 1512(c)(2) applies to corrupt acts—including by public officials— that frustrate the commencement or conduct of a proceeding, and not just to acts that make evidence unavailable or impair its integrity. Section 1512(c)(2)’s breadth is reinforced by the similarity of its language to the omnibus clause of 18 U.S.C. § 1503, which covers anyone who “corruptly . . . obstructs, or impedes, or endeavors to influence, obstruct, or impede, the due administration of justice.” That clause of Section 1503 follows two more specific clauses that protect jurors, judges, and court officers. The omnibus clause has nevertheless been construed to be “far more general in scope than the earlier clauses of the statute.” United States v. Aguilar, 515 U.S. 593, 599 (1995). “The omnibus clause is essentially a catch-all provision which generally prohibits
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