The Third Circuit has determined that a South Carolina conviction for accessory after the fact does not qualify as an obstruction of justice aggravated felony. In South Carolina, accessory after the fact occurs where the defendant, knowing that a principal has committed a felony, “harbor[s] or assist[s] the principal felon . . . for the purpose of enabling the principal felon to escape detection or arrest.” The court noted that this offense focused not on a defendant’s intent and actions regarding a particular judicial proceeding, but on the principal of a crime. Because "there are infinite actions a defendant may undertake with the intent to aid the principal after the commission of a crime, but before the commencement of judicial proceedings," there is no causal nexus between the South Carolina statute and the federal conceptions of obstruction of justice.
The full text of Flores v. Attorney General can be found here:
http://www2.ca3.uscourts.gov/opinarch/161979p.pdf