The United States Court of Appeals for the Second Circuit in Manhattan affirmed Mr. Marinello’s conviction, stating that the “omnibus clause criminalizes corrupt interference with an official effort to administer the tax code, and not merely a known I.R.S. investigation.”

He argued for a narrower reading of the omnibus clause because “at some point, prosecutors must encounter boundaries to discretion, so that no American prosecutor can say, ‘Show me the man and I’ll find you the crime.’”

He objected to the obstruction charge brought under a provision known as the “omnibus clause,” making it a crime for a person who “corruptly” or by force or by threats of force “obstructs or impedes, or endeavors to obstruct or impede, the due administration of” the Internal Revenue Service laws.

The idea of divorce continued to spread throughout the country, and certain states used the vagueness of the omnibus clause to entice new residents by promising them easy divorces.

But these tell very little, except that it is easier or more congenial to use one or another of the statutory causes, just as the old "omnibus clause," which gave general discretion to the courts in Connecticut, and still more in some other States, was made to cover many cases.