A plea in juvenile delinquency proceedings is neither a conviction nor an admission of a "crime" for purposes of triggering inadmissibility for a crime of moral turpitude or controlled substances offense.  The BIA ruled that the same holds true when the person becomes an adult, although the Ninth Circuit, without actually discussing the issue, came to another conclusion.  A noncitizen who formally admits all of the elements of a controlled substance crime or a crime involving moral turpitude can be found inadmissible. INA 212(a)(2)(A)(i), 8 USC 1182(a)(2)(A)(i). See discussion at 3.8 (controlled substance offense) and 4.4 (moral turpitude offense). The Board of Immigration Appeals, however, held that an admission made by a minor or adult about such an offense committed when the person was a minor does not trigger inadmissibility under these grounds, because the admission is of committing juvenile delinquency, not a controlled substance or moral turpitude "crime." Matter of MU, 2 I&N Dec. 92 (BIA 1944) (admission by adult of activity while a minor is not an admission of committing a crime involving moral turpitude triggering inadmissibility); but see US v. Gutierrez-Alba, 128 F.3d 1324 (9th Cir. 1997) (without discussion of issue of juvenile delinquency, juveniles guilty plea in adult criminal proceedings constitutes admission, regardless of whether adult criminal court prosecution was ineffective due to defendants minority status). This is in keeping with consistent holdings of the Board of Immigration Appeals "that acts of juvenile delinquency are not crimes for immigration purposes." Matter of Devison, Int. Dec. 3435 (BIA 2000)(en banc), citing Matter of C.M., 5 I&N Dec. 327 (BIA 1953), Matter of Ramirez-Rivero, 18 I&N Dec. 135 (BIA 1981). In Devison the Board held that this longstanding rule was not changed by the 1996 enactment of a statutory definition of conviction at 8 USC 1101(a)(48)(A), INA 101(a)(48)(A). K. Brady, Cal. Crim. L. and Immigration 2A.4 (2004).