Whether the Petitioner was denied due process and equal protection when the court failed to allow him to withdraw his guilty plea under Padilla v. Kentucky and Strickland v. Washington, given that the guilty plea required his removal as an alien despite his eligibility to remain in the U.S. as a legal permanent resident

QUESTION PRESENTED ~ I. The U.S. Court of Appeals for the Tenth Cir: ; cuit, in review, sustained the Federal District Court Judge’s (FDDJ) denial of Petitioner’s Petition for Writ of Error Coram Nobis to withdraw his guilty plea, and thus failed to allow the Petitioner to withdraw his guilty plea under Padilla v. Kentucky, 559 U.S. 356 (2010), and Strickland v. Washington, 466 U.S. 688, under circumstances which the guilty plea statutorily required the removal of an alien yet unauthorized to, but eligible to remain in the United States as a legal permanent resident of the United States with employment authorization, under 8 U.S. C. § 1229b(b)(1) INA § 240A(b)(1) Cancellation of Removal and Adjustment of Status of Certain ; Nonpermanent Residents, alien whose U.S. ii citizen daughter will suffer exceptional and extremely unusual hardship, here suffering from the most extreme form of spina bifida, if her alien father is removed from the United States, and where it is impossible for the Petitioner, as Defendant in the criminal case, to have committed the crime of which he was ac_~ . cused and to which he pled guilty, because he . ; is not an employer, as an element of the crime, . .or in collusion with an employer, but rather merely used false documents bearing his own . name to obtain employment, and could not o have used the documents to “verify” his employment as that confusing, technical term is meant pursuant to INA § 274A(b), 8 U.S: C. ; §1324a(b), and thereby, as a practical matter, eliminating the INA § 240A, 8 U.S. C § 1229b(b)(1) humanitarian remedy from the . : law. The conviction was void on its face because with its several references, only an em; ployer, or employing agency, can “verify” and thus commit this crime, and, as the record iii shows, the alien only used false documents to obtain employment and was not in collusion or conspiracy with the employer to defraud : the government's Unlawful Employment of Alien’s program.