I'm not sure of that. He now enjoys the presumption of immunity, but a (hypothetical) prosecution still has the option of attempting to prove that his obstructions were not done under color of office. It is possible to succeed, for instance in the GA case the defense tried to claim that all mangolini's actions attempting to overturn the GA election results were acts under office. I guess the bar to the prosecution is a little higher now, having to disprove act of office rather than the defense having to prove act of office.