If "the deportation consequences of a particular plea are unclear or uncertain…a criminal defense attorney need do no more than advise a noncitizen client that pending criminal charges may carry a risk of adverse immigration consequences." Padilla v. Kentucky, 559 U.S. 356, 369 (2010). When a defense attorney decides to do more, by incorrectly qualifying the risk as "very low" and mis-advising that the plea is "immigration friendly," does this incorrect advice render nugatory the general advisement about the risk of adverse immigration consequences, thereby rendering the defense attorney's assistance ineffective?

Ineffective-assistance-of-counsel