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"The defendant-appellant (Juarez) appeals the district court’s decision on his ineffective assistance of counsel claim. Juarez’s counsel failed to independently research and investigate the derivative citizenship defense. Citizenship is a defense to the alienage element of both crimes to which Juarez pled guilty. Juarez claims that his counsel’s performance was deficient and prejudicial when counsel advised him to enter guilty pleas without consulting available jurisprudence to make an informed or competent decision. For the following reasons, we REVERSE and REMAND." USA v. Juarez, Feb. 24, 2012. [Hats off to Laura Fletcher Leavitt, Assistant Federal Public Defender!]