On remand from the Supreme Court in light of Loper Bright, the Second Circuit has again denied a petition for review filed by a Hong Kong-born lawful permanent resident found removable for two crimes involving moral turpitude, one of which was a New Jersey disorderly persons offense for theft by deception.
Applying independent judgment rather than deferring to the BIA's interpretation, the Court held that a "conviction" under 8 U.S.C. § 1101(a)(48)(A) means a formal judgment of guilt reached through a proceeding affording the accused core criminal-procedural protections and resulting in a criminal sentence, regardless of how a state labels the offense or what collateral consequences it carries. Because the petitioner's disorderly persons proceeding provided those protections and exposed him to potential incarceration, the Court held it was a conviction under the INA and again denied his petition.
The full text of Wong v. Blanche can be found here: https://ww3.ca2.uscourts.gov/decisions/OPN/22-6185_2_opn.pdf