The following excerpt is from United States v. Door, 996 F.3d 606 (9th Cir. 2021):
10 But see United States v. Rubio , 317 F.3d 1240, 124445 (11th Cir. 2003) (holding retaliatory purpose sufficient because Application Note 4(i) to U.S.S.G. 3C1.1 authorizes an enhancement based upon any conduct prohibited by the obstruction of justice provisions of Title 18, including 18 U.S.C. 1513(b), which prohibits a person from inflicting bodily injury on a witness with the intent to retaliate).
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