Criminal Defense of Immigrants

(F)  Deferred Adjudication.  The BIA has held that deferred adjudication dispositions constitute convictions, even though a direct appeal could be started in the event of a violation of the deferred adjudication program, followed by imposition of a formal judgment and sentence.[188]  These decisions, however, appear to limit their holdings concerning finality to the deferred adjudication context, and they have not been extended to invalidate direct appeal as a means of avoiding finality of conviction.

[188] Matter of Punu, 22 I. & N. Dec. 224 (BIA 1998) (en banc).