The following excerpt is from U.S. v. Burrell, 289 F.3d 220 (2nd Cir. 2002):
Acts that a conspiracy defendant commits as a minor in furtherance of a conspiracy are admissible to show his participation in the conspiracy if the defendant ratifies his participation in the conspiracy after his eighteenth birthday as Banks, who was eighteen at the time of his second arrest, did. United States v. Delatorre, 157 F.3d 1205, 1209-10 (10th Cir.1998); United States v. Welch, 15 F.3d 1202, 1211-12 (1st Cir.1993); United States v. Doerr, 886 F.2d 944, 969-70 (7th Cir.1989); cf. United States v. Wong, 40 F.3d 1347, 1363-68 (2d Cir.1994) (allowing consideration of pre-eighteen acts in a RICO prosecution where defendant continued his participation after his eighteenth birthday). Thus, Banks' juvenile plea allocution was properly admitted.
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