Obstruction

 Washington Post: Trump can be charged with obstruction after high court ruling, filing says, Special counsel Jack Smith said in a new filing that a Supreme Court ruling tossing an obstruction count against some Jan. 6 defendants does not help Trump. By Spencer S. Hsu and Perry Stein

...the Supreme Court explained that [the obstruction statute]’s criminal prohibition includes ‘creating false evidence,’” namely “fraudulent electoral certificates..."