Matter of Batista-Hernandez,
21 I. & N. Dec. 955 (BIA July 15, 1997) (federal conviction
pursuant to 18 U.S.C. § 3 as accessory after the fact to a
drug-trafficking crime establishes deportability as an aggravated
felony under former INA § 241(a)(2)(A)(iii), because the offense
of accessory after the fact falls within the definition of
an obstruction of justice crime under INA § 101(a)(43)(S),
8 U.S.C. § 1101(a)(43)(S)).