United States v. Rainey, No. 13-30770 (5th Cir. 2014)
Annotate this CaseThis criminal prosecution stemmed from BP's response to the explosion on the Deepwater Horizon drilling rig in April 2010. Defendant, BP's former Vice President of Exploration for the Gulf of Mexico, contended that he could not be prosecuted under 18 U.S.C. 1505 for obstructing a congressional-subcommittee investigation because a congressional subcommittee is not "any committee of either House." The district court agreed and dismissed the obstruction count. The court interpreted the statutory class of "any committee of either House," to include congressional subcommittees. The court vacated and remanded, concluding that the indictment adequately alleged that defendant obstructed an investigation by a "committee of either House," and also that defendant knew of the investigation.
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