(E)  Non-Criminal Dispositions.  A number of dispositions exist that do not constitute “convictions” of crimes for immigration purposes, including juvenile adjudications in juvenile court, and minor non-criminal violations or infractions resulting from a procedure that cannot result in incarceration.  See § § 7.22-7.26, infra.

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).