What is the current state of the law on the grounds of obstruction of justice and perjury?

In the present case, the district court enhanced Albizu's sentence for obstruction of justice based on its finding that Albizu (1) proffered to the district court, prior to trial and through his attorney, materially false information concerning the facts underlying Albizu's duress defense; and (2) testified falsely at trial to a substantial portion of the events alleged. See Appendix for the United States at 47-50. Both perjury, which in this context has been defined as "false testimony concerning a material matter with the willful intent to provide false testimony, rather than as a result of confusion, mistake, or faulty memory," United States v. Dunnigan, 507 U.S. 87, 94 (1993), and "providing false information to a judge or magistrate," are appropriate grounds on which to base an enhancement for obstructing justice. See USSG 3C1.1, comments. (n.3(b)), (n.3(f)).