Obstructive act. Obstruction -of-justice law "reach es all corrupt conduct capable of
producing an effect that prevents justice from being duly administered , regardless of the mean s
employed." United States v. Silverman , 745 F.2d 1386, 1393 (11th Cir. 1984) (interpreting 18
U.S.C . § 1503). An "effort to influence " a proceeding can qualify as an endeavor to obstruct
justice even if the effort was "subtle or circuitous" and "however cleverly or with whatever
cloaking of purpose " it was made . United States v. Roe, 529 F.2d 629, 632 (4th Cir. 1975); see
also United States v. Quattrone, 441 F.3d 153, 173 (2d Cir. 2006). The verbs "' obstruct or impede '
are broad " and "can refer to anything that blocks , makes difficult, or hinders ." Marinello v. United
States , 138 S. Ct. 1101, 1106 (2018) (internal brackets and quotation marks omitted).
An improper motive can render an actor ' s conduct criminal even when the conduct would
otherwise be lawful and within the actor's authority. See United States v. Cueto, 151 F .3d 620,
631 (7th Cir . 1998) (affirming obstruction conviction of a criminal defense attorney for "litigation -
related conduct ") ; United States v. Cintolo, 818 F .2d 980, 992 (1st Cir. 1987) ("any act by any
party-wh ether lawful or unlawful on its face - may abridge § 1503 if performed with a corrupt
motive ")