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).