What is the current state of the law on obstruction of justice?

"The imposition of an obstruction-of-justice enhancement is subject to a mixed standard of review. We review de novo the sentencing court's interpretation of the Sentencing Guidelines but review its related findings of fact only for clear error." United States v. Fiore, 381 F.3d 89, 92 (2d Cir. 2004) (internal quotation marks and citation omitted). To qualify for the enhancement based on perjury, "a sentencing court must find that the defendant 1) willfully 2) and materially 3) committed

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perjury, which is (a) the intentional (b) giving of false testimony (c) as to a material matter." United States v. Zagari, 111 F.3d 307, 329 (2d Cir. 1997).