Renteria-Morales v. Mukasey, 551 F.3d 1076 (9th Cir. Dec. 12, 2008), withdrawing previous opinion, 532 F.3d 949 (9th Cir. July 10, 2008) (aggravated felony obstruction of justice involves: (a) active interference with proceedings of a tribunal or investigation, or action or threat of action against those who would cooperate in the process of justice; and (b) the specific intent to interfere with the process of justice; no meaning distinction exists between failing to appear for court proceedings and hindering a third party from appearing; "Although misprision of felony or fleeing arrest may obstruct justice in a general sense, neither act interferes with judicial process and thus both offenses are different in kind than generic obstruction-of-justice offenses."), following Matter of Espinoza-Gonzalez, 22 I. & N. Dec. 889, 893 (BIA 1999).