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6 which an overarching statute applies. Thus, by 1996, Congress had used the same phrase for the same purpose to refer to §1503. In fact, the INA’s list of aggravated felonies explicitly cross-references RICO, suggesting Congress was well aware of the parallel. See §1101(a)(43)(J) (INA listing RICO violation as an aggravated felony).

In short, in searching for the heartland of obstruction of justice, the omnibus clause of §1503 and the history from which it is derived are invaluable touchstones. Neither countenances an obstruction of justice offense separate from a pending investigation or proceeding.

Even setting this crucial historical evidence aside, and