The Fourth Circuit has determined that a deferred adjudication program which requires a defendant to plead guilty at the outset still qualifies as a conviction if the judge imposes probation.  The Court noted that it would have reached a different outcome if the defendant had not been required to enter a guilty plea.  The Court recognized that its decision created "a disparity between defendants who plead guilty under the Virginia first offender statute and those who plead not guilty."

The full text of Payan-Jaquez v. Sessions can be found here: