## Facts

- A federal district judge learned that an acquaintance’s name appeared on an authorized federal wiretap used in a criminal investigation.
- The judge told the acquaintance about the wiretap, disclosing that interception had been authorized; the authorization for that particular wiretap had expired by the time of the disclosure.
- During a later FBI interview connected to a grand jury investigation, the judge denied knowing anything about the wiretap and asked whether he was a target.
- The government charged the judge with (1) obstruction of justice under 18 U.S.C. § 1503, based on false statements to FBI agents, and (2) unlawful disclosure of a wiretap under 18 U.S.C. § 2232(c), based on alerting the acquaintance.
- A jury convicted on both counts; the court of appeals reversed both convictions.

## Issues

1. Whether false statements to FBI agents, standing alone, can constitute obstruction of justice under 18 U.S.C. § 1503 when the agents might later testify before a grand jury.
2. Whether 18 U.S.C. § 2232(c) prohibits disclosure of a wiretap after the authorization for the interception has expired.

## Decision

- The Supreme Court held that § 1503 requires a “nexus” between the obstructive act and a particular judicial or grand jury proceeding, and affirmed reversal of the obstruction conviction.
- The Court concluded the evidence showed only that the defendant lied to investigators, making any effect on the grand jury too speculative to satisfy the nexus and intent requirements.
- The Court held that § 2232(c) applies even if the interception authorization has expired at the time of the disclosure.
- The Court rejected the court of appeals’ narrower reading of § 2232(c) and remanded for further proceedings consistent with its interpretation.

## Legal Principles

- Under 18 U.S.C. § 1503’s Omnibus Clause, obstruction requires a sufficient nexus: the act must relate to a judicial or grand jury proceeding “in time, causation, or logic” and have the “natural and probable effect” of interfering with that proceeding.
- A defendant must act with intent to influence a judicial or grand jury proceeding; intent to affect an ancillary investigation, without a meaningful connection to the proceeding, is insufficient.
- Knowledge that one’s conduct is likely to affect a pending (or contemplated) proceeding is central to proving the requisite intent to obstruct.
- Under 18 U.S.C. § 2232(c), it is enough that the defendant knows interception “has been authorized” (or an application has been made); the statute does not require the authorization to be currently in effect at the moment of disclosure.
- Disclosure that notice of possible interception was given “in order to obstruct, impede, or prevent” interception can fall within § 2232(c) even after the authorization period ends, if the other statutory elements are met.

## Conclusion

The Court narrowed § 1503 by requiring a concrete nexus between obstructive conduct and a specific judicial or grand jury proceeding, while interpreting § 2232(c) to cover wiretap-disclosure conduct even when the particular interception authorization has expired.


United States v. Aguilar, 515 U.S. 593 (1995)