State of Washington v. Jose Antonio Manajares

¶1 In Padilla v. Kentucky, 559 U.S. 356, 367, 130 S. Ct. 1473, 176 L. Ed. 2d 284 (2010), the United States Supreme Court held that constitutionally competent counsel must advise a client facing criminal charges about the risk of deportation. In In re Personal Restraint of Yung-Cheng Tsai, our Supreme Court held that while Padilla created a “new rule” under federal law for retroac-tivity purposes, Washington has long required by statute that criminal defendants be advised of immigration consequences of a guilty plea, so Padilla simply applied a Washington lawyer’s duty to a specific concern.…