Convictions of minor offenses, or even of major offenses, which are punished in a perfunctory manner as "non-judicial punishment," do not constitute convictions of "crimes," and thus cannot trigger deportation under any of the deportation grounds requiring criminal convictions. This is true because no incarceration is possible as a result of this minor and informal procedure, and because the procedure cannot be called a criminal procedure so as to result in a criminal conviction of a crime. See Matter of Eslamizar, 23 I. & N. Dec. 684 (BIA Oct. 19, 2004) (en banc).

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