(B)  Conduct-Based Immigration Consequences of Crimes.  Many different grounds of deportation, and other adverse immigration consequences of crimes, are based on status or “conduct,” rather than upon a criminal conviction.  See § 7.7, infra.  These conduct-based immigration consequences are not necessarily avoided by avoiding or eliminating a criminal conviction, since they depend upon what the client did out there in the streets, and altering a conviction does not change the historical facts of what the client actually did.

Sixth Circuit

CONVICTION - COLLATERAL ATTACK IN REMOVAL PROCEEDINGS NOT PERMITTED
Al-Najar v. Mukasey, __ F.3d __, 2008 WL 245632 (6th Cir. Jan. 31, 2008) (petitioner's challenge to the state court conviction in immigration court constituted an impermissible collateral attack).