United States v. Fidel Mendez, 765 F.3d 950

In 2007, a Washington juvenile court adjudicated Mendez guilty of second-degree unlawful possession of a firearm, a crime that can be a felony if committed by an adult.
In 2012, after becoming an adult, Mendez was charged in federal court with 18 U.S.C. § 922(g)(1) based on the 2007 adjudication.
The indictment alleged the 2007 juvenile adjudication satisfied the predicate for a conviction under § 922(g)(1).
Mendez moved to dismiss arguing his 2007 adjudication is not a conviction of a crime punishable by more than one year under federal law.
Congress directs that whether a person has a conviction shall be determined by the law of the jurisdiction where proceedings occurred.
Washington law allows juvenile adjudications to be treated as convictions when the offender is an adult and has committed a crime under the adult system.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 2007 juvenile adjudication can serve as a conviction for §922(g)(1).	Mendez: juvenile adjudication is not a conviction under state law for purposes of §922(g)(1).	United States: Washington treats juvenile adjudications as convictions once in the adult system for predicate crimes.	Yes; the 2007 juvenile adjudication qualifies as a conviction.

United States v. Valerio, 441 F.3d 837 (9th Cir. 2006) (determine validity of state-law approach for convictions under §922(g)(1))
State v. Johnson, 76 P.3d 265 (Wash. Ct. App. 2003) (juvenile adjudications can be used in adult sentencing contexts)
State v. Wright, 946 P.2d 792 (Wash. Ct. App. 1997) (juvenile adjudications can serve as predicates for offenses in adult system)
State v. McKinley, 929 P.2d 1145 (Wash. Ct. App. 1997) (juvenile adjudications may be used as prior convictions for certain crimes)
Monroe v. Soliz, 939 P.2d 205 (Wash. 1997) (juveniles are deemed to commit violations, not crimes, within juvenile system)
In re Frederick, 604 P.2d 953 (Wash. 1980) (policy context on juvenile adjudications as non-crimes in certain contexts)