By Nicholas Hartmann and Harry Sandick (March 25, 2018, 11:03 AM EDT) -- In a 7-2 decision authored by Justice Stephen Breyer, Marinello v. United States, the U.S. Supreme Court added the so-called "omnibus clause" of 26 U.S.C. § 7212(a) to the growing list of obstruction statutes in need of some "interpretive 'restraint.'"[1] The omnibus clause forbids "corruptly ... obstruct[ing] or imped[ing], or endeavor[ing] to obstruct or impede, the due administration of [the Internal Revenue Code]."[2] The majority analogized the omnibus clause to 18 U.S.C. § 1503, which was construed by the court in United States v. Aguilar in 1995. Like the omnibus clause, Section 1503 makes it a crime to "corruptly ... influence[], obstruct[], or impede[] ... the due administration of justice." The court held that the omnibus clause, like Section 1503, must be interpreted to prohibit only obstructive conduct that has a "nexus" to a particular proceeding....