Submission of Immaterial False Docs Qualifies for Obstruction Enhancement

U.S. v. Wardell, 2007 WL 64834 (1/11/07)(unpub'd) - Under U.S.S.G. § 3C1.1, & n. 4(c), the submission of false documents constitutes obstruction of justice even if the documents are immaterial. The 10th could not figure out why the Sentencing Commission treats false documents differently from other false statements, but that's what the plain language says. So there. The defendant's submission of false documents that did not help his case warranted an obstruction of justice enhancement.