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Hiding information from an investigation to avoid prosecution of yourself or others is obstruction of justice.

Refusing to identify the leak is contempt (not obstruction) and they were held in contempt.



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I guess I'm not understanding this distinction here.



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I said that unclearly. If physical evidence already exists -- documents, the "smoking gun," etc. -- and it is subpoenaed, you must produce it. If you hide it, claim it doesn't exist, or destroy it, that could be obstruction.

If something exists in your mind, you can not be convicted of a crime for failing to speak (although you may be held in contempt unless you have the right not to speak). If you do speak under oath and you lie, it is perjury. In certain circumstances, the perjury might also constitute obstruuction.