Prior Juvenile Dispositions Arguably Do Not Disqualify Noncitizens From Effective FFOA Treatment Under Lujan

If a noncitizen has a first adult conviction of simple possession of a controlled substance, or any other such conviction of a qualifying offense, there is an argument that prior juvenile dispositions for controlled substances offenses should not disqualify the noncitizen from effectively eliminating adverse its immigration consequences under Lujan-Armendariz v. INS, 222 F.3d 728 (9th Cir.