(B)  Youthful Offender Sentences.  A formal commitment of a defendant to an institution such as the California Youth Authority (CYA), as opposed to a commitment to the California Department of Corrections with a recommendation that the defendant be housed in CYA, does not constitute a sentence to confinement for immigration purposes.[101]  If counsel can obtain a CYA commitment, the sentence will not be considered a sentence to confinement.

 

[101] Matter of N, 8 I. & N. Dec. 660 (BIA 1960); cf. Matter of Goodalle, 12 I. & N. Dec. 106 (BIA 1967) (term in N.Y. State Reformatory did constitute a sentence). 

Other

CRIMINAL DEFENSE - SENTENCE
M. Shein, Cultural Issues in Sentencing, in L. FRIEDMAN RAMIREZ, ED., CULTURAL ISSUES IN CRIMINAL DEFENSE 625 (2d ed. 2007).