which held that juvenile adjudications that do not afford the right to a jury trial and require a beyond-a-reasonable doubt burden of proof do not fit within Apprendi's exception for prior convictions. But at least three jurisdictions have disagreed with the holding in Tighe. See Jones, 382 F.8d at 698 (rejecting defendant's contention that Apprendi requires holding that prior non-jury juvenile adjudications that afforded all required due process safeguards cannot be used to enhance sentence under Armed Career Criminal Act); Smalley, 294 F.3d at 1033 (concluding juvenile adjudications can be characterized as "prior convictions" for Apprendi purposes and, thus, district court did not err when it enhanced defendant's sentence based on prior juvenile convictions); Hitt, 42 P.3d at 786 (<HOLDING>). After reviewing the decisions in all of the
holding that a juvenile adjudication may be used as a prior conviction for apprendi purposes holding that juvenile adjudications are prior convictions for purposes of the apprendi exception and indicating that the main concern in apprendi was whether the prior convictions procedural safeguards ensured a reliable result not that there had to be a right to a jury trial holding apprendi exception for prior convictions encompasses juvenile adjudications holding that juvenile adjudications may not be used for impeachment purposes because the disposition of a juvenile does not constitute a criminal conviction holding that the prior conviction exception should not extend to nonjury juvenile adjudications