February 2012
COA Rules Padilla Isn't Retroactive
The Michigan Court of Appeals ruled that Padilla v Kentucky, 130 S Ct 1473; 176 L Ed 2d 284 (2010) is not retroactive. Padilla held that defense counsel had to tell a non-citizen about the deportation of the consequences of his/her plea. People v Gomez, Court of Appeals No. 320485.