the juvenile justice system is much more punitive than its founders envisaged. Lawyers also appear to be reluctant to appeal juvenile cases and to seek postconviction relief; heavy caseloads, a prevalent view that appeals undermine the rehabilitation process, and an absence of awareness among juveniles of their appeal rights are the likely reasons for this reluctance. Welch, 604 F.3d at 431-432 (Posner, J., dissenting). {¶ 30} State supreme courts also are divided on this issue. Compare State v. Harris, 339 Or. 157, 175, 118 P.3d 236 (2005) (the Sixth Amendment requires a juvenile adjudication that is offered as an enhancement factor to increase a criminal sentence to either be proved to a trier of fact or be admitted by a defendant), and State v. Brown, 879 So.2d 1276, 1289 (La.2004) (<HOLDING>), with Ryle v. State, 842 N.E.2d 320, 323
holding that a guilty plea for which the defendant received a deferred adjudication counted as a conviction under federal law for purposes of ussg  4b11 holding that a nonjury juvenile adjudication that  afforded all constitutionallyrequired procedural safeguards can properly be characterized as a prior conviction for apprendi purposes holding that felony conviction for which imposition of sentence was stayed could be counted as prior felony conviction under sentencing guidelines holding that a juvenile adjudication should not be counted as a prior conviction for apprendi purposes holding that a juvenile adjudication could not constitute a conviction for purposes of hawaiis repeat offender provision