Matter of Joseph,
22 I. & N. Dec. 799, 808 (BIA May 28, 1999) ("[I]t
is substantially unlikely that the offense of simply obstructing
or hindering ones own arrest will be viewed as an obstruction
of justice aggravated felony under INA § 101(a)(43)(S), 8
U.S.C. § 1101(a)(43)(S) of the Act for removal purposes.").