573 U.S. 169, 188 n.10 (2014) (internal quotation marks omitted). The rule has been cited, for example, in adopting a narrow meaning of “tangible object” in an obstruction statute when the prohibition’s title, history, and list of prohibited acts indicated a focus on destruction of records. See Yates v. United States, 135 S. Ct. 1074, 1088 (2015) (plurality opinion) (interpreting “tangible object” in the phrase “record, document, or tangible object” in 18 U.S.C. § 1519 to mean an item capable of recording or preserving information). Here, as discussed above, the text, structure, and history of Section 1512(c)(2) leaves no “grievous ambiguity” about the statute’s meaning. Section 1512(c)(2) defines a structurally independent general prohibition on obstruction of official proceedings. 5. Other Obstruction Statutes Might Apply to the Conduct in this Investigation Regardless whether Section 1512(c)(2) covers all corrupt acts that obstruct, influence, or impede pending or contemplated proceedings, other statutes would apply to such conduct in pending proceedings, provided that the remaining statutory elements are satisfied. As discussed above, the omnibus clause in 18 U.S.C. § 1503(a) applies generally to obstruction of pending judicial and grand 1084 proceedings. See Aguilar, 515 U.S. at 598 (noting that the clause is “far more general in scope” than preceding provisions). Section 1503(a)‘s protections extend to witness tampering and to other obstructive conduct that has a nexus to pending proceedings. See Sampson, 898 F.3d at 298-303 & n.6 (collecting cases from eight circuits holding that Section 1503 covers witness-related obstructive conduct, and cabining prior circuit authority). And Section 1505 broadly criminalizes obstructive conduct aimed at pending agency and congressional 1085 proceedings. See, e.g., United States v. Rainey, 757 F.3d 234, 241-247 (5th Cir. 2014). Finally, 18 U.S.C. § l 512(b)(3) criminalizes tampering with witnesses to prevent the communication of information about a crime to law enforcement. The nexus inquiry articulated in Aguilar—that an individual has “knowledge that his actions are likely to affect the judicial proceeding,” 515 U.S. at 599—does not apply to Section 1512(b)(3). See United States v. Byrne, 435 F.3d 16, 24-25 (1st Cir. 2006). The nexus inquiry turns instead on the actor’s intent to prevent communications to a federal law enforcement official. See Fowler v. United States, 563 U.S. 668, 673-678 (2011).
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