The Fourth Circuit has determined that a Virginia conviction for accessory after the fact is an obstruction of justice aggravated felony. In so doing, the court deferred to the agency’s definition of obstruction of justice, which does not require an ongoing investigation into the crime.

The full text of Pugin v. Garland can be found here:

https://www.ca4.uscourts.gov/opinions/201363.P.pdf

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