United States v. Aguilar

Summary

The Court held that obstruction under § 1503 requires a nexus between the defendant's conduct and a judicial proceeding, including knowledge that the conduct is likely to affect that proceeding. Aguilar's false statements to investigating FBI agents did not satisfy that requirement on this record. The Court also held that § 2232(c) can prohibit disclosure of an expired wiretap authorization and rejected Aguilar's argument for narrowing that statute on First Amendment grounds. It affirmed the reversal of the obstruction conviction, reversed the ruling concerning the wiretap-disclosure conviction, and remanded. Justice Stevens agreed with the obstruction disposition and rejection of the First Amendment argument but would have affirmed the entire appellate judgment because § 2232(c) requires a pending application or existing authorization. Justice Scalia, joined by Justices Kennedy and Thomas, agreed with the Court's wiretap analysis but would also have upheld the obstruction conviction, rejecting the nexus requirement as inconsistent with the statute's prohibition of an endeavor to obstruct justice.