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U.S. v. Clayton, No. 97-60712 (5th Cir.) (172 F.3d 347) (April 12, 1999) (Judge E. Grady Jolly)

The Court held that any obstructive conduct must occur after an investigation has begun and cited the Sentencing Commission's statements that its amendments to § 3C1.1 were meant to clarify "the temporal element of the obstruction guideline (i.e., that the obstructive conduct must occur during the investigation, prosecution, or sentencing ...

 

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