Hugo Reyes-Morales v. Maryland

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?