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Rule 2.00 (Obstruction) Comment: ... It is entirely up to the judgment of the umpire as to whether a fielder is in the act of fielding a ball. After a fielder has made an attempt to field a ball and missed, he can no longer be in the “act of fielding” the ball. ...
Since the fielder simply misplayed the throw before any contact occurred, I would concur that it probably should have been obstruction.
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