Salazar-Luviano v. Mukasey, 551 F.3d 857 (9th Cir. Dec. 23, 2008) (federal conviction of Aiding and Abetting an Escape from Custody, in violation of 18 U.S.C. 751, did not categorically qualify as an "obstruction of justice" aggravated felony, within the meaning of INA 101(a)(43)(S), 8 U.S.C. 1101(a)(43)(S), so respondent is therefore eligible for cancellation of removal under INA 240A(a): "Because a violation of 18 U.S.C. 751 does not require the existence of a pending judicial proceeding, much less knowledge of or specific intent [footnote omitted] to obstruct such a proceeding, one could violate 751 while serving a sentence in federal prison after the conclusion of all judicial proceedings, for example, or (as here) while in detention before the commencement of any judicial proceedings. Under either circumstance, a person attempting to escape from custody would fail all three elements of obstructing justice under 1503."), following Matter of Espinoza-Gonzalez, 22 I. & N. Dec. 889, 892 (BIA 1999) ("Thus, the question whether a specific offense of conviction counts as an aggravated felony under 1101(a)(43)(S) depends exclusively on whether "the elements of the offense ... constitute the crime of obstruction of justice as that term is defined" in the federal criminal law, U.S.Code Title 18, Chapter 73 (18 U.S.C. 1501-1521).").