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In Padilla v. Kentucky, 130 S.Ct. 1473 (2010), the U.S. Supreme Court held that criminal defense attorneys have a Sixth Amendment obligation to inform their non-citizen clients of the potential consequences of pleading guilty to offenses that might make them deportable. Petitioner Jose Padilla, a lawful permanent resident of the United States for 40 years, sought to reopen his criminal case because his criminal defense attorney told him he did not have to worry about his immigration status because of his long duration as a permanent resident in the United States. In fact, Mr. Padilla’s drug conviction made him deportable as both a controlled substance offender and as an aggravated felon drug trafficker. See 8 USC §1227(a)(2)(B)(i) and 8 USC §1101(a)(43)(B). The Court held that:

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