The Ninth Circuit has determined that a California conviction for dissuading a witness by force or fear qualifies an obstruction of justice aggravated felony if accompanied by a sentence of at least one year of incarceration. In so doing, the Court analyzed the conduct criminalized by all three subsections of California Penal Code section 136.1, and found they all match the generic definition of obstruction of justice.
The full text of Godoy-Aguilar v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2025/01/13/19-70960.pdf