AGGRAVATED FELONY - CRIME OF VIOLENCE
United States v. Mosley, 575 F.3d 603 (6th Cir. Jul. 23, 2009) (Michigan conviction of resisting and obstructing a police officer, under Mich. Comp. Laws 750.81d(1) ("assaults, batters, wounds, resists, obstructs, opposes, or endangers a person whom the individual knows or has reason to know is performing his or her duties."), is not a crime of violence for purposes of the Armed Career Criminal Act, since obstructing does not contain an element of force or create a substantial risk that force will be used in committing the offense).

BIA

MISPRISION OF FELONY - OBSTRUCTION OF JUSTICE
Matter of Espinoza, 22 I. & N. Dec. 889 (BIA June 11, 1999) (en banc) (federal conviction for misprision of a felony under 18 U.S.C. § 4 does not constitute a conviction for an aggravated felony under INA § 101(a)(43)(S), 8 U.S.C. § 1101(a)(43)(S), as an offense relating to obstruction of justice), distinguishing Matter of Batista-Hernandez, 21 I. & N. Dec. 955 (BIA July 15, 1997)).

HINDERING ONES OWN ARREST - OBSTRUCTION OF JUSTICE
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.").

ACCESSORY AFTER THE FACT - OBSTRUCTION OF JUSTICE
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)).

AGGRAVATED FELONY - OBSTRUCTION OF JUSTICE
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).").

Second Circuit

AGGRAVATED FELONY " OBSTRUCTION OF JUSTICE " WITNESS TAMPERING
Higgins v. Holder, 677 F.3d 97 (2d Cir. Apr. 19, 2012) (Connecticut conviction for witness tampering under General Statutes 53a-151 ["if, believing that an official proceeding is pending or about to be instituted, he induces or attempts to induce a witness to testify falsely, withhold testimony, elude legal process summoning him to testify or absent himself from any official proceeding,"] categorically constituted an "offense relating to obstruction of justice" under INA 101(a)(43)(S), 8 U.S.C. 1101(a)(43)(S), and thus was an aggravated felony that precluded LPR cancellation). Note: The facts involved asking the victim to say "nothing happened" if she talked to the police.

Fifth Circuit

AGGRAVATED FELONY " OBSTRUCTION OF JUSTICE " ACCESSORY AFTER THE FACT
United States v. Gamboa-Garcia, ___ F.3d ___ (5th Cir. Sept. 22, 2010) (Idaho convictions for violation of Idaho Code 18-205, for being accessory after the fact to murder, was an aggravated felony obstruction of justice offense to constitute an obstruction of justice aggravated felony under INA 101(a)(43)(S), 8 U.S.C. 1101(a)(43)(S). for illegal re-entry sentencing purposes). Note: The court here did not address the issue of whether an obstruction of justice offense must interfere with a court proceeding to constitute an obstruction of justice aggravated felony under INA 101(a)(43)(S), 8 U.S.C. 1101(a)(43)(S). CD:19.80, 19.15;AF:5.2, 5.63, A.31, A.2, B.31, B.62

CONTEMPT OF COURT - OBSTRUCTION OF JUSTICE
Alwan v. Ashcroft, 388 F.3d 507 (5th Cir. Oct. 18, 2004) (federal conviction of contempt of court, under 18 U.S.C. § 401(3), was one "relating to obstruction of justice," and thus an "aggravated felony" for immigration purposes).

Eighth Circuit

AGGRAVATED FELONY " OBSTRUCTION OF JUSTICE " OBSTRUCTION OF LEGAL PROCESS
Ortiz v. Lynch, __ F.3d __ (8th Cir. Aug. 6, 2015) (Minnesota conviction for violation of Minn.Stat. 609.50, subd. 2(2), obstruction of legal process, is not an aggravated felony crime of violence under 8 U.S.C. 1101(a)(43)(F), INA 101(a)(43)(F), since the minimum amount of force required to sustain a conviction under the obstruction of legal process is not violent force as required by 18 U.S.C. 16).

Ninth Circuit

AGGRAVATED FELONY " OBSTRUCTION OF JUSTICE " RENDERING CRIMINAL ASSISTANCE
Hoang v. Holder, ___ F.3d ___, 2011 WL 1885989 (9th Cir. May 17, 2011) (Washington conviction of misdemeanor rendering criminal assistance in the second degree, to a person who committed a felony, by providing such person transportation, in violation of Wash. Rev. Code 9A.76.080, did not categorically constitute an aggravated felony crime related to obstruction of justice under INA 101(a)(43)(S), 8 U.S.C. 1101(a)(43)(S), because a person could be convicted of violating this statute if to one whom s/he provided transportation s/he knows has committed a crime, before any investigation or judicial proceeding has begun; generic federal obstruction of justice requires that defendant commit an act involving either active interference with proceedings of a tribunal or investigation, or action or threat of action against those who would cooperate with the process of justice.); quoting Matter of Espinoza"Gonzalez, 22 I. & N. Dec. 889, 893 (BIA 1999) (en banc).

AGGRAVATED FELONY - FAILURE TO APPEAR - FAILURE TO APPEAR
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) (federal conviction of failure to appear, in violation of 18 U.S.C. 3146, qualifies as an aggravated felony obstruction of justice conviction, under INA 101(a)(43)(S), 8 U.S.C. 1101(a)(43)(S), if a sentence of one year or more was imposed, because the statute requires an intentional failure to appear; conviction is not an aggravated felony "failure to appear" conviction, under INA 101(a)(43)(T), 8 U.S.C. 1101(a)(43)(T).)

AGGRAVATED FELONY - OBSTRUCTION OF JUSTICE - FAILURE TO APPEAR
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) (federal conviction of failure to appear, in violation of 18 U.S.C. 3146, qualifies as an aggravated felony obstruction of justice conviction, under INA 101(a)(43)(S), 8 U.S.C. 1101(a)(43)(S), if a sentence of one year or more was imposed, because the statute requires an intentional failure to appear; conviction is not an aggravated felony "failure to appear" conviction, under INA 101(a)(43)(T), 8 U.S.C. 1101(a)(43)(T).)

AGGRAVATED FELONY - FAILURE TO APPEAR - FAILURE TO APPEAR
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) (federal conviction of failure to appear, in violation of 18 U.S.C. 3146, is broader than the aggravated felony definition of failure to appear, under INA 101(a)(43)(T), since 18 U.S.C. 3146 can be violated by failing to appear for a misdemeanor, for reasons other than to dispose of a charge, and based upon orders other than those issued by a court).

Eleventh Circuit

OBSTRUCTION OF JUSTICE
Oguejiofor v. Attorney General of U.S., 277 F.3d 1305 (11th Cir. Jan. 2, 2002) (conviction of obstruction of justice constituted an aggravated felony under INA § 101(a)(43)(S), 8 U.S.C. § 1101(a)(43)(S) for removal purposes).