§ 12.10 III. Noncitizen Minors in Adult and Youthful Offender Proceedings
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JUVENILES " CONVICTION " EXISTENCE OF CONVICTION
Hanna v. Holder, 740 F.3d 379 (6th Cir. Jan. 17, 2014) (adjudication under Michigan's Holmes Youthful Trainee Act (YTA), Mich. Comp. Laws 762.11"16, is a conviction under the INA, since it is more similar to a deferred adjudication for youthful offenders than a true finding of juvenile delinquency); following Uritsky v. Gonzales, 399 F.3d 728, 735 (6th Cir. 2005) (YTA adjudications are convictions under 8 U.S.C. 1101(a)(48)(A), because they are not analogous to determinations of juvenile delinquency under the Federal Juvenile Delinquency Act (FJDA), 18 U.S.C. 5031"42).
BIBLIOGRAPHY " JUVENILE " COLLATERAL CONSEQUENCES OF CALIFORNIA JUVENILE DELINQUENCY CASES
Pacific Juvenile Defender Center, Everything You Need to Know About Adverse Results of a Juvenile Arrest, Prosecution, or Adjudication in California Collateral Consequences of Juvenile Delinquency Proceedings in California: A Handbook for Juvenile Law Practitioners (2012).