United States v. Baker, No. 05-1739, 2006 WL 328293 (2d Cir. Feb. 13, 2006)
One question (in Vermont, at least).
At trial, Baker took the stand and, according to the district court, "thwarted the government's attempt to impeach him by refusing to answer a question directly relevant to direct examination, despite the court's insruction for him to do so." Well, the court must have been pretty ticked with Baker because it found that his refusal to answer that solitary question merited a 2 level enhancement to his Guidelines offense level for obsruction of justice (U.S.S.G. 3C1.1). And then the Second Circuit, giving the district court "due deference in its application of the Guidelines to the facts," affirmed the enhancement.
Yes, Baker should have answered the question. But 2 offense levels seems like an awfully severe penalty for a defendant who is not otherwise accused of having testified falsely.