(E)  State Adult Dispositions for Offenses Not Transferable to Adult Court Under the FJDA.  The cases holding foreign adult dispositions of noncitizens under 18 at the time of the offense are not convictions for immigration purposes can be used to argue that analogous state convictions for such offenses should likewise not constitute convictions.  See § 12.18, 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).