In Pugin v. Garland, the Court reviewed "whether an offense 'relat[es] to obstruction of justice' under §1101(a)(43)(S) even if the offense does not require that an investigation or proceeding be pending. Dictionary definitions, federal laws, state laws, and the Model Penal Code show that the answer is yes: An offense “relat[es] to obstruction of justice” even if the offense does not require that an investigation or proceeding be pending." Jake Leahy, Host.