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, with a sentence imposed of one year
or more, establishes deportability as an aggravated felony,
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)).