To say that this does not in itself rise to the level of "obstruction of justice" is to empty that concept of all meaning. Obstruction of justice was the first count in the articles of impeachment against Nixon and, years later, a countagainst Bill Clinton. In Clinton's case, the ostensible obstruction consisted solely in lying under oath about a sordid sexual affair that may have sullied the Oval Office but involved no abuse of presidential power as such.