The Third Circuit has determined that a special court martial qualifies as a conviction for immigration purposes even though the court martial need necessarily be presided over by a judge.  The court acknowledged several characteristics of a special court martial that make it similar to a criminal court proceeding.  Specifically, the consequences of a finding of guilt are similar, and defendants in both proceedings enjoy similar rights.  

The full text of Gourzong v. Attorney General can be found here: 

http://www2.ca3.uscourts.gov/opinarch/152645p.pdf

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