Can a defendant be convicted of obstruction of justice for providing "material false information" to a judge or magistrate in a presentence interview?

The question whether a defendant's conduct amounts to an obstruction of justice involves an interpretation of the Guidelines which we review de novo. United States v. Rodriguez-Razo, 962 F.2d 1418, 1420 (9th Cir.1992). The adjustment is appropriate when a defendant "provid[es] materially false information to a judge or magistrate" or "to a probation officer in respect to a presentence report or other investigation for the court." U.S.S.G. 3C1.1, comment. (n. 3(f) and (g)). We have expressly rejected a defendant's argument that false testimony does not constitute obstruction where the government can consult official records for the truth. United States v. Gonzalez-Mares, 752 F.2d 1485, 1491-92 (9th Cir.), cert. denied, 473 U.S. 913 (1985) (upholding conviction for obstruction under 18 U.S.C. 1503). "Requiring the probation officer to complete a thorough check on the defendant defeats the speed and convenience of the oral presentence report system...." Id. at 1492. Moreover, we have held "material" a defendant's failure to disclose prior convictions sustained under another name. Rodriguez-Razo, 962 F.2d at 1421. "A misstatement concerning prior convictions made at a presentence interview affects the length of sentence, which is the issue under determination." Id. (citation omitted).