Mejia Rodriguez v. U.S. Department of Homeland Security, U.S., 2011 U.S. App. LEXIS 49

Mejia, a Honduran national, entered the U.S. in 1980 on a B-2 visa and overstayed, ultimately facing deportation.
He received temporary protected status (TPS) after Hurricane Mitch and renewals were allowed from 1999 to 2004.
In 2005 DHS CIS denied renewal based on prior convictions; most were later vacated, leaving a 1985 turnstile-jumping conviction and the 1986 alleged
"conviction" at issue.
In 1986 Mejia was charged with marijuana possession and driving with a suspended license; the state court disposed of the case with a guilty plea, a finding of guilt, and credit for time served.
The central question is whether the 1986 guilty plea and its disposition qualify as a 'conviction' under 8 U.S.C. § 1101(a)(48).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mejia's 1986 guilty plea constitutes a 'conviction' under § 1101(a)(48).	Mejia argues no adjudication or punishment is shown by the record.	DHS contends the plea with adjudication and sentence satisfies § 1101(a)(48).	Yes; the plea, guilt finding, and time served constitute a formal judgment of guilt.

Puello v. Bureau of Citizenship and Immigration Servs., 511 F.3d 324 (2d Cir. 2007) (formal judgment concept for conviction analysis)
Griffiths v. INS, 243 F.3d 45 (1st Cir. 2001) (withheld adjudication not controlling when adjudication shown)
United States v. Anderson, 328 F.3d 1326 (11th Cir. 2003) (time served can satisfy 'punishment' under §1101(a)(48))
Corey v. United States, 375 U.S. 169 (1963) (sentence is the judgment; final judgment equates to punishment)
Singh v. Holder, 568 F.3d 525 (5th Cir. 2009) (adopts Rule 32(k)(1)-like analogy for 'formal judgment of guilt')
Dickerson v. New Banner Inst., Inc., 460 U.S. 103 (1983) (federal-law approach to sentencing concepts in conviction analysis)
Resendiz-Alcaraz v. U.S. Att'y Gen., 383 F.3d 1262 (11th Cir. 2004) (uniform federal definition of conviction)