Maybe not in those words, but it can be argued he was

Posted on: December 2, 2019 at 09:28:08 CT

“Impeachment is perhaps Congress’s most potent way to hold government officials accountable. And in the past, Congress has cited obstruction of congressional oversight as a basis for impeaching a president. The second article of impeachment against President Richard Nixon included the allegation that he failed to act “when he knew or had reason to know that his close subordinates endeavoured to impede and frustrate lawful inquiries by duly constituted ... legislative entities.” The third article of impeachment cited Nixon for having failed “without lawful cause or excuse to produce papers and things as directed by duly authorized subpoenas issued by the Committee on the Judiciary of the House of Representatives ... and willfully disobeyed such subpoenas.” In other words, the House Judiciary Committee approved articles of impeachment against Nixon for obstructing congressional oversight.”

https://www.acslaw.org/expertforum/why-obstruction-of-congressional-investigations-could-be-grounds-for-impeachment/

Additionally it is strongly implied in Article 1, sections 3&4

3. approving, condoning, acquiescing in, and counselling witnesses with respect to the giving of false or misleading statements to lawfully authorized investigative officers and employees of the United States and false or misleading testimony in duly instituted judicial and congressional proceedings;

4. interfering or endeavouring to interfere with the conduct of investigations by the Department of Justice of the United States, the Federal Bureau of Investigation, the office of Watergate Special Prosecution Force, and Congressional Committees;