STATE OF MARYLAND v. JUAN CARLOS SANMARTIN PRADO
Court of Appeals, Watts, July 11, 2016,
Ineffective Assistance – Deportation – Not ineffective assistance of counsel where attorney advised during colloquy that it was a “deportable offense” and also advised before plea that there “probably would be immigration consequences.” No need to advise on whether deportation is guaranteed.

Is it really necessary to provide a 3-paragraph analysis of every result in a nationwide Lexis search for “deportable”? You looked over the cases; we believe you! A 1-2 paragraph synthesis would be just fine

Guilty plea – An “agreed statement of facts” is the functional equivalent of a guilty plea for purposes of advisement of immigration consequences

Cites last year’s Smith case on coram nobis

The USSC in Padilla held that counsel must inform his client whether the plea carries a risk of deportation

Rule 4-242(f)(1) – Requires “only that a noncitizen defendant be alerted that he or she may face immigration consequences.” No requirement regarding advice as to whether an offense is deportable. May be done off the record.