(C)  Foreign Dispositions.  Where a noncitizen is arrested abroad for an offense committed while under 18 years of age, and convicted in adult court, a question arises whether the adult-court disposition constitutes a conviction for immigration purposes.  If the offense is one for which no transfer from juvenile to adult court is authorized by the Federal Juvenile Delinquency Act, the foreign disposition is not considered to be a conviction.  See § 12.14, infra.

Sixth Circuit

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).

Other

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).