The following excerpt is from United States v. Johnson, 812 F.3d 757 (9th Cir. 2016):
defendant's conduct actually hindered the government's efforts. Destroying or concealing evidence "contemporaneously with arrest" does not "warrant an adjustment for obstruction unless it results in a material hindrance to the official investigation or prosecution of the instant offense or the sentencing of the offender." Id. 3C1.1 cmt. 4(D). Making "a materially false statement to a law enforcement officer" may be enhanced only if the statement "significantly obstructed or impeded the official investigation or prosecution of the instant offense." Id. 3C1.1 cmt. 4(G); see also United States v. SolanoGodines, 120 F.3d 957, 964 (9th Cir.1997) ("[A]ctual, significant hindrance to investigation is necessary when false aliases are given, not under oath, during the investigation." (emphasis added) (quoting United States v. Urbanek, 930 F.2d 1512, 1515 n. 2 (10th Cir.1991) )).
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.