"Generally speaking, to obtain and sustain an obstruction conviction, the government would need to prove beyond a reasonable doubt that a person, acting with corrupt intent, engaged in obstructive conduct with a sufficient nexus to a pending or contemplated proceeding. ...[T]he report identifies no actions that... constitute obstructive conduct, had a nexus to a pending or contemplated proceeding, and were done with corrupt intent... beyond a reasonable doubt..."
January 1, 1970
https://en.wikiquote.org/wiki/Mueller_Report