In Matter of Eslamizar, 23 I. & N. Dec. 684 (BIA Oct. 19, 2004) (en banc) (court procedures under Ore. Rev. Stat. 153.076, did not constitute a conviction for immigration purposes, since the proceedings do not allow a jury trial, right to court-appointed counsel, or proof beyond a reasonable doubt), overruling Matter of CR, 8 I. & N. Dec. 59 (BIA 1958) (police court adjudication of petty theft under a municipal ordinance, on a standard of preponderance of the evidence, constituted a conviction for immigration purposes), the BIA held a finding of petty theft under Oregon minor offense procedure did not constitute a conviction for immigration purposes, since it was not a criminal proceeding in which the normal procedural rights, such as jury trial, the right to appointed counsel, and the presumption of innocence were not respected. The Board, however, distinguished foreign convictions: "[N]othing in our decision should be taken as asserting that a foreign conviction must adhere to all the requirements of the United States Constitution applicable to criminal trials, including that relating to the requisite standard of proof. Rather, we find that Congress intended that the proceeding must, at a minimum, be criminal in nature under the governing laws of the prosecuting jurisdiction, whether that may be in this country or in a foreign one." (Id. at ___ [footnote omitted].) The Board also indicated: "We have found that Congress intended other limitations with respect to the recognition of foreign convictions for immigration purposes, holding, inter alia, that a foreign conviction must be for conduct recognized as criminal by United States standards in order to be deemed a crime under the immigration laws. See Matter of De La Nues, 18 I&N Dec. 140 (BIA 1981); Matter of McNaughton, 16 I&N Dec. 569 (BIA 1978), aff'd, 612 F.2d 457 (9th Cir. 1980).