The Ninth Circuit addressed the statutory definition of a "conviction" for immigration purposes and held that it includes a formal judgment of guilt entered by a court, even if the case is still on direct appeal or if sentencing is not final. The court justified this departure from a long line of precedent, including a Supreme Court memorandum decision, based on IIRAIRA's creation in 1996 of a statutory definition of "conviction." The Ninth held that the plain language of the statute mandated its holding.
I invite my readers to suggest arguments on why this holding might be wrong.
Read the opinion at http://www.ca9.uscourts.gov/datastore/opinions/2011/07/05/07-70730.pdf