CA2 on Coram Nobis, Strickland, Prejudice: Kovacs v. U.S.

CA2 on Coram Nobis, Strickland, Prejudice: Kovacs v. U.S.

"We conclude that a defense lawyer’s incorrect advice about the immigration consequences of a plea is prejudicial if it is shown that, but for counsel’s unprofessional errors, there was a reasonable probability that the petitioner could have negotiated a plea that did not impact immigration status or that he would have litigated an available defense. ... Kovacs has established his claim of ineffective assistance of counsel and satisfies the requirements for coram nobis relief. Therefore, we reverse and remand to the district court with instructions to issue the writ and vacate Kovacs’ conviction." - Kovacs v. U.S., Mar. 3, 2014.  [Hats off to Nicholas A. Gravante, Jr.!]