United States v. David Rainey

HIGGINSON, Circuit Judge:

Distilled, this appeal raises a pure question of statutory interpretation. Congress criminalizes obstructing “the due and proper exercise of the power of inquiry under which any inquiry or investigation is being had by either House, or any committee of either House or any joint committee of the Congress.” 18 U.S.C. § 1505. The defendant contends, and the district court agreed, that he cannot be prosecuted under § 1505 for obstructing a congressional-subcommittee investigation because a congressional subcommittee is not “any committee of either House.” We interpret the…