The Ninth Circuit has determined that a California conviction for accessory after the fact to a felony is not categorically an aggravated felony related to obstruction of justice because it encompasses conducted related to crimes which are not the subject of an ongoing investigation or proceeding.
The full text of Valenzuela Gallardo v. Barr can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2020/08/06/18-72593.pdf