Whether the Court's plain error analysis is properly applied to violations of Fed. R. Crim. P. 32(i)(1)(A), and, if so, whether such violations are structural

question presented is: Whether the Court’s plain error analysis is properly applied to violations of Fed. R. Crim. P. 32()(1)(A), and, if so, whether such violations are structural. 2. Also in this case, the Court of Appeals upheld an enhancement for obstruction of justice under U.S.S.G. § 3C1.1 where Petitioner induced a girlfriend to submit a false written statement to the police claiming she owned the firearm at issue in Petitioner’s case. There was no evidence in the record that law enforcement ever believed her or took any action on account of this false statement. Under the Application Note 5(b), this enhancement does not apply for “making false statements, not under oath, to law enforcement officers, unless Application Note 4(g) above applies.” U.S.S.G. § 3C1.1, Note 5(b). Note 4(g) references “providing a materially false statement to a law enforcement officer that significantly obstructed or impeded the official investigation or prosecution of the instant offense.” U.S.S.G. § 3C1.1, Note 4(g). The second question presented, therefore, is: ‘ Whether procuring a false statement to police not under oath which does not in fact significantly impede an investigation is a proper basis for enhancement under U.S.8.G. § 3C1.1. ii