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Rh for the conclusion that core obstruction of justice requires the administration of justice.

When Congress codified chapter 73 in 1948, the chapter contained six provisions, each of which requires a connection to a pending proceeding or investigation. See Act of June 25, 1948, §§1501–1506, 62 Stat. 769–770. The central provision is §1503, with its omnibus or catchall prohibition against endeavoring “to influence, obstruct, or impede, the due administration of justice.” As already explained,, it is undisputed that §1503’s omnibus clause requires a pending proceeding. The same is true for the other five provisions, all of which either refer to ongoing legal processes or cover conduct that can arise only during legal proceedings.

By the time Congress passed 8 U. S. C. §1101(a)(43)(S) in 1996, Congress had added nine narrower, more specific offenses to the six original offenses (§§1501–1506) in chapter 73. See 18 U. S. C. §§1507–1513, 1516–1517. While it is less clear that those specialized provisions fall within the heartland of obstruction of justice, even the vast majority of them require a connection to a proceeding or investigation.