ALITO, J., CONCURRING IN JUDGMENT
PADILLA V. KENTUCKY
559 U. S. ____ (2010)
SUPREME COURT OF THE UNITED STATES
NO. 08-651
JOSE PADILLA, PETITIONER
v. KENTUCKY
on writ of certiorari to the supreme court of
kentucky
[March 31, 2010]
Justice Alito, with whom The
Chief Justice joins, concurring in the judgment.
I concur in the judgment because
a criminal defense attorney fails to provide effective assistance
within the meaning of
Strickland v.
Washington,
466 U. S. 668
(1984), if the attorney misleads a noncitizen client regarding the
removal consequences of a conviction. In my view, such an attorney
must (1) refrain from unreasonably providing incorrect advice and
(2) advise the defendant that a criminal conviction may have
adverse immigration consequences and that, if the alien wants
advice on this issue, the alien should consult an immigration
attorney. I do not agree with the Court that the attorney must
attempt to explain what those consequences may be. As the Court
concedes, “[i]mmigration law can be complex”; “it is a legal
specialty of its own”; and “[s]ome members of the bar who represent
clients facing criminal charges, in either state or federal court
or both, may not be well versed in it.”
Ante, at 11. The
Court nevertheless holds that a criminal defense attorney must
provide advice in this specialized area in those cases in which the
law is “succinct and straightforward”—but not, perhaps, in other
situations.
Ante, at 11–12. This vague, halfway test will
lead to much confusion and needless litigation.
I
Under
Strickland, an
attorney provides ineffective assistance if the attorney’s
representation does not meet reasonable professional standards. 466
U. S., at 688. Until today, the longstanding and unanimous position
of the federal courts was that reasonable defense counsel generally
need only advise a client about the
direct consequences of
a criminal conviction. See,
e.g.,
United States
v
. Gonzalez, 202 F. 3d 20, 28 (CA1 2000)
(ineffective-assistance-of-counsel claim fails if “based on an
attorney’s failure to advise a client of his plea’s immigration
consequences”);
United States v.
Banda, 1 F. 3d
354, 355 (CA5 1993) (holding that “an attorney’s failure to advise
a client that deportation is a possible consequence of a guilty
plea does not constitute ineffective assistance of counsel”); see
generally Chin & Holmes, Effective Assistance of Counsel and
the Consequences of Guilty Pleas, 87 Cornell L. Rev. 697, 699
(2002) (hereinafter Chin & Holmes) (noting that “virtually all
jurisdictions”—including “eleven federal circuits, more than thirty
states, and the District of Columbia”—“hold that defense counsel
need not discuss with their clients the collateral consequences of
a conviction,” including deportation). While the line between
“direct” and “collateral” consequences is not always clear, see
ante, at 7, n. 8, the collateral-consequences rule
expresses an important truth: Criminal defense attorneys have
expertise regarding the conduct of criminal proceedings. They are
not expected to possess—and very often do not possess—expertise in
other areas of the law, and it is unrealistic to expect them to
provide expert advice on matters that lie outside their area of
training and experience.
This case happens to involve
removal, but criminal convictions can carry a wide variety of
consequences other than conviction and sentencing, including civil
commitment, civil forfeiture, the loss of the right to vote,
disqualification from public benefits, ineligibility to possess
firearms, dishonorable discharge from the Armed Forces, and loss of
business or professional licenses. Chin & Holmes 705–706. A
criminal conviction may also severely damage a defendant’s
reputation and thus impair the defendant’s ability to obtain future
employment or business opportunities. All of those consequences are
“seriou[s],” see
ante, at 17, but this Court has never
held that a criminal defense attorney’s Sixth Amendment duties
extend to providing advice about such matters.
The Court tries to justify its dramatic
departure from precedent by pointing to the views of various
professional organizations. See
ante, at 9 (“The weight of
prevailing professional norms supports the view that counsel must
advise her client regarding the risk of deportation”). However,
ascertaining the level of professional competence required by the
Sixth Amendment is ultimately a task for the courts.
E.g.,
Roe v.
Flores-Ortega,
528 U. S. 470, 477
(2000). Although we may appropriately consult standards promulgated
by private bar groups, we cannot delegate to these groups our task
of determining what the Constitution commands. See
Strickland,
supra, at 688 (explaining that
“[p]revailing norms of practice as reflected in American Bar
Association standards … are guides to determining what is
reasonable, but they are only guides”). And we must recognize that
such standards may represent only the aspirations of a bar group
rather than an empirical assessment of actual practice.
Even if the only relevant consideration were
“prevailing professional norms,” it is hard to see how those norms
can support the duty the Court today imposes on defense counsel.
Because many criminal defense attorneys have little understanding
of immigration law, see
ante, at 11, it should follow that
a criminal defense attorney who refrains from providing immigration
advice does not violate prevailing professional norms. But the
Court’s opinion would not just require defense counsel to warn the
client of a general
risk of removal; it would also require
counsel in at least some cases, to specify what the removal
consequences of a conviction would be. See
ante,
at 11–12
.
The Court’s new approach is particularly
problematic because providing advice on whether a conviction for a
particular offense will make an alien removable is often quite
complex. “Most crimes affecting immigration status are not
specifically mentioned by the [Immigration and Nationality Act
(INA)], but instead fall under a broad category of crimes, such as
crimes involving moral turpitude or
aggravated
felonies.” M. Garcia & L. Eig, CRS Report for Congress,
Immigration Consequences of Criminal Activity (Sept. 20, 2006)
(summary) (emphasis in original). As has been widely acknowledged,
determining whether a particular crime is an “aggravated felony” or
a “crime involving moral turpitude [(CIMT)]” is not an easy task.
See R. McWhirter, ABA, The Criminal Lawyer’s Guide to Immigration
Law: Questions and Answers 128 (2d ed. 2006) (hereinafter ABA
Guidebook) (“Because of the increased complexity of aggravated
felony law, this edition devotes a new [30-page] chapter to the
subject”);
id., §5.2, at 146 (stating that the aggravated
felony list at 8 U. S. C. §1101(a)(43) is not clear with
respect to several of the listed categories, that “the term
‘aggravated felonies’ can include misdemeanors,” and that the
determination of whether a crime is an “aggravated felony” is made
“even more difficult” because “several agencies and courts
interpret the statute,” including Immigration and Customs
Enforcement, the Board of Immigration Appeals (BIA), and Federal
Circuit and district courts considering immigration-law and
criminal-law issues); ABA Guidebook §4.65, at 130 (“Because nothing
is ever simple with immigration law, the terms ‘conviction,’ ‘moral
turpitude,’ and ‘single scheme of criminal misconduct’ are terms of
art”);
id., §4.67, at 130 (“[T]he term ‘moral turpitude’
evades precise definition”).
Defense counsel who consults a guidebook on
whether a particular crime is an “aggravated felony” will often
find that the answer is not ‘‘easily ascertained.” For example, the
ABA Guidebook answers the question “Does simple possession count as
an aggravated felony?” as follows: “Yes,
at least in the Ninth
Circuit.” §5.35, at 160 (emphasis added). After a dizzying
paragraph that attempts to explain the evolution of the Ninth
Circuit’s view, the ABA Guidebook continues: “Adding to the
confusion, however, is that the Ninth Circuit has conflicting
opinions depending on the context on whether simple drug possession
constitutes an aggravated felony under 8 U. S. C.
§1101(a)(43).”
Id., §5.35, at 161 (citing cases
distinguishing between whether a simple possession offense is an
aggravated felony “for immigration purposes” or for “sentencing
purposes”). The ABA Guidebook then proceeds to explain that
“
attempted possession,”
id., §5.36, at 161
(emphasis added), of a controlled substance
is an
aggravated felony, while “[c]onviction under the federal
accessory after the fact statute is
probably
not an aggravated felony, but a conviction for accessory
after the fact to the manufacture of methamphetamine
is an
aggravated felony,”
id., §537, at 161 (emphasis added).
Conspiracy or attempt to commit drug trafficking are aggravated
felonies, but “[s]olicitation is not a drug-trafficking offense
because a generic solicitation offense is not an offense related to
a controlled substance and therefore not an aggravated felony.”
Id., §5.41, at 162.
Determining whether a particular crime is one
involving moral turpitude is no easier. See
id., at 134
(“Writing bad checks
may or may not be a CIMT” (emphasis
added));
ibid. (“[R]eckless assault coupled with an
element of injury, but not serious injury, is
probably not
a CIMT” (emphasis added));
id., at 135 (misdemeanor
driving under the influence is generally not a CIMT, but may be a
CIMT if the DUI results in injury or if the driver knew that his
license had been suspended or revoked);
id., at 136 (“If
there is no element of actual injury, the endangerment offense
may not be a CIMT” (emphasis added));
ibid.
(“Whether [a child abuse] conviction involves moral turpitude
may depend on the subsection under which the individual is
convicted. Child abuse done with criminal negligence
probably is not a CIMT” (emphasis added)).
Many other terms of the INA are similarly
ambiguous or may be confusing to practitioners not versed in the
intricacies of immigration law. To take just a few examples, it may
be hard, in some cases, for defense counsel even to determine
whether a client is an alien,[
Footnote 1] or whether a particular state disposition will
result in a “conviction” for purposes of federal immigration
law.[
Footnote 2] The task of
offering advice about the immigration consequences of a criminal
conviction is further complicated by other problems, including
significant variations among Circuit interpretations of federal
immigration statutes; the frequency with which immigration law
changes; different rules governing the immigration consequences of
juvenile, first-offender, and foreign convictions; and the
relationship between the “length and type of sentence” and the
determination “whether [an alien] is subject to removal, eligible
for relief from removal, or qualified to become a naturalized
citizen,” Immigration Law and Crimes §2:1, at 2–2 to 2–3.
In short, the professional organizations and
guidebooks on which the Court so heavily relies are right to say
that “nothing is ever simple with immigration law”—including the
determination whether immigration law clearly makes a particular
offense removable. ABA Guidebook §4.65, at 130; Immigration Law and
Crimes §2:1. I therefore cannot agree with the Court’s apparent
view that the Sixth Amendment requires criminal defense attorneys
to provide immigration advice.
The Court tries to downplay the severity of
the burden it imposes on defense counsel by suggesting that the
scope of counsel’s duty to offer advice concerning deportation
consequences may turn on how hard it is to determine those
consequences. Where “the terms of the relevant immigration statute
are succinct, clear, and explicit in defining the removal
consequence[s]” of a conviction, the Court says, counsel has an
affirmative duty to advise the client that he will be subject to
deportation as a result of the plea.
Ante, at 11. But
“[w]hen the law is not succinct and straightforward … , 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.”
Ante, at 11–12. This approach
is problematic for at least four reasons.
First, it will not always be easy to tell
whether a particular statutory provision is “succinct, clear, and
explicit.” How can an attorney who lacks general immigration law
expertise be sure that a seemingly clear statutory provision
actually means what it seems to say when read in isolation? What if
the application of the provision to a particular case is not clear
but a cursory examination of case law or administrative decisions
would provide a definitive answer? See Immigration Law and Crimes
§2:1, at 2–2 (“Unfortunately, a practitioner or respondent cannot
tell easily whether a conviction is for a removable offense… .
[T]he cautious practitioner or apprehensive respondent will not
know conclusively the future immigration consequences of a guilty
plea”).
Second, if defense counsel must provide advice
regarding only one of the many collateral consequences of a
criminal conviction, many defendants are likely to be misled. To
take just one example, a conviction for a particular offense may
render an alien excludable but not removable. If an alien charged
with such an offense is advised only that pleading guilty to such
an offense will not result in removal, the alien may be induced to
enter a guilty plea without realizing that a consequence of the
plea is that the alien will be unable to reenter the United States
if the alien returns to his or her home country for any reason,
such as to visit an elderly parent or to attend a funeral. See ABA
Guidebook §4.14, at 111 (“Often the alien is both
excludable and
removable. At times, however, the
lists are different. Thus, the oddity of an alien that is
inadmissible but not deportable. This alien should not leave the
United States because the government will not let him back in”
(emphasis in original)). Incomplete legal advice may be worse than
no advice at all because it may mislead and may dissuade the client
from seeking advice from a more knowledgeable source.
Third, the Court’s rigid constitutional rule
could inadvertently head off more promising ways of addressing the
underlying problem—such as statutory or administrative reforms
requiring trial judges to inform a defendant on the record that a
guilty plea may carry adverse immigration consequences. As
amici point out, “28 states and the District of Columbia
have
already adopted rules, plea forms, or statutes
requiring courts to advise criminal defendants of the possible
immigration consequences of their pleas.” Brief for State of
Louisiana et al. 25; accord, Chin & Holmes 708 (“A growing
number of states require advice about deportation by statute or
court rule”). A nonconstitutional rule requiring trial judges to
inform defendants on the record of the risk of adverse immigration
consequences can ensure that a defendant receives needed
information without putting a large number of criminal convictions
at risk; and because such a warning would be given on the record,
courts would not later have to determine whether the defendant was
misrepresenting the advice of counsel. Likewise, flexible statutory
procedures for withdrawing guilty pleas might give courts
appropriate discretion to determine whether the interests of
justice would be served by allowing a particular defendant to
withdraw a plea entered into on the basis of incomplete
information. Cf.
United States v.
Russell, 686
F. 2d 35, 39–40 (CADC 1982) (explaining that a district
court’s discretion to set aside a guilty plea under the Federal
Rules of Criminal Procedure should be guided by, among other
considerations, “the possible existence of prejudice to the
government’s case as a result of the defendant’s untimely request
to stand trial” and “the strength of the defendant’s reason for
withdrawing the plea, including whether the defendant asserts his
innocence of the charge”).
Fourth, the Court’s decision marks a major
upheaval in Sixth Amendment law. This Court decided
Strickland in 1984, but the majority does not cite a
single case, from this or any other federal court, holding that
criminal defense counsel’s failure to provide advice concerning the
removal consequences of a criminal conviction violates a
defendant’s Sixth Amendment right to counsel. As noted above, the
Court’s view has been rejected by every Federal Court of Appeals to
have considered the issue thus far. See,
e.g.,
Gonzalez, 202 F. 3d, at 28;
Banda, 1
F. 3d, at 355; Chin & Holmes 697, 699. The majority
appropriately acknowledges that the lower courts are “now quite
experienced with applying
Strickland,”
ante, at
14, but it casually dismisses the longstanding and unanimous
position of the lower federal courts with respect to the scope of
criminal defense counsel’s duty to advise on collateral
consequences.
The majority seeks to downplay its dramatic
expansion of the scope of criminal defense counsel’s duties under
the Sixth Amendment by claiming that this Court in
Hill v.
Lockhart,
474 U. S. 52 (1985),
similarly “applied
Strickland to a claim that counsel had
failed to advise the client regarding his parole eligibility before
he pleaded guilty.”
Ante, at 14. That characterization of
Hill obscures much more than it reveals. The issue in
Hill was whether a criminal defendant’s Sixth Amendment
right to counsel was violated where counsel misinformed the client
about his eligibility for parole. The Court found it “unnecessary
to determine whether there may be circumstances under which
erroneous advice by counsel as to parole eligibility may be deemed
constitutionally ineffective assistance of counsel, because in the
present case we conclude that petitioner’s allegations are
insufficient to satisfy the
Strickland v.
Washington requirement of ‘prejudice.’ ” 474 U. S.,
at 60. Given that
Hill expressly and unambiguously refused
to decide whether criminal defense counsel must
avoid
misinforming his or her client as to
one consequence
of a criminal conviction (parole eligibility), that case plainly
provides no support whatsoever for the proposition that counsel
must
affirmatively advise his or her client as to
another collateral consequence (removal). By the Court’s
strange logic,
Hill would support its decision here even
if the Court had held that misadvice concerning parole eligibility
does
not make counsel’s performance objectively
unreasonable. After all, the Court still would have “applied
Strickland” to the facts of the case at hand.
II
While mastery of immigration law
is not required by
Strickland, several considerations
support the conclusion that affirmative misadvice regarding the
removal consequences of a conviction may constitute ineffective
assistance.
First, a rule prohibiting
affirmative misadvice regarding a matter as crucial to the
defendant’s plea decision as deportation appears faithful to the
scope and nature of the Sixth Amendment duty this Court has
recognized in its past cases. In particular, we have explained that
“a guilty plea cannot be attacked as based on inadequate legal
advice unless counsel was not ‘a reasonably competent attorney’ and
the advice was not ‘within the range of competence demanded of
attorneys
in criminal cases.’ ”
Strickland,
466 U. S., at 687 (quoting
McMann v.
Richardson,
397 U. S. 759,
770, 771 (1970); emphasis added). As the Court appears to
acknowledge, thorough understanding of the intricacies of
immigration law is not “within the range of competence demanded of
attorneys
in criminal cases.” See
ante, at 11
(“Immigration law can be complex, and it is a legal specialty of
its own. Some members of the bar who represent clients facing
criminal charges, in either state or federal court or both, may not
be well versed in it”). By contrast, reasonably competent attorneys
should know that it is not appropriate or responsible to hold
themselves out as authorities on a difficult and complicated
subject matter with which they are not familiar. Candor concerning
the limits of one’s professional expertise, in other words, is
within the range of duties reasonably expected of defense attorneys
in criminal cases. As the dissenting judge on the Kentucky Supreme
Court put it, “I do not believe it is too much of a burden to place
on our defense bar the duty to say, ‘I do not know.’ ” 253
S. W. 3d 482, 485 (2008).
Second, incompetent advice distorts the
defendant’s decisionmaking process and seems to call the fairness
and integrity of the criminal proceeding itself into question. See
Strickland, 466 U. S., at 686 (“In giving meaning to the
requirement [of effective assistance of counsel], we must take its
purpose—to ensure a fair trial—as the guide”). When a defendant
opts to plead guilty without definitive information concerning the
likely effects of the plea, the defendant can fairly be said to
assume the risk that the conviction may carry indirect consequences
of which he or she is not aware. That is not the case when a
defendant bases the decision to plead guilty on counsel’s express
misrepresentation that the defendant will not be removable. In the
latter case, it seems hard to say that the plea was entered with
the advice of constitutionally competent counsel—or that it
embodies a voluntary and intelligent decision to forsake
constitutional rights. See
ibid. (“The benchmark for
judging any claim of ineffectiveness must be whether counsel’s
conduct so undermined the proper functioning of the adversarial
process that the trial cannot be relied on as having produced a
just result”).
Third, a rule prohibiting unreasonable
misadvice regarding exceptionally important collateral matters
would not deter or interfere with ongoing political and
administrative efforts to devise fair and reasonable solutions to
the difficult problem posed by defendants who plead guilty without
knowing of certain important collateral consequences.
Finally, the conclusion that affirmative
misadvice regarding the removal consequences of a conviction can
give rise to ineffective assistance would, unlike the Court’s
approach, not require any upheaval in the law. As the Solicitor
General points out, “[t]he vast majority of the lower courts
considering claims of ineffective assistance in the plea context
have [distinguished] between defense counsel who remain silent and
defense counsel who give affirmative misadvice.” Brief for United
States as
Amicus Curiae 8 (citing cases). At
least three Courts of Appeals have held that affirmative misadvice
on immigration matters can give rise to ineffective assistance of
counsel, at least in some circumstances.[
Footnote 3] And several other Circuits have held that
affirmative misadvice concerning nonimmigration consequences of a
conviction can violate the Sixth Amendment even if those
consequences might be deemed “collateral.”[
Footnote 4] By contrast, it appears that no court of
appeals holds that affirmative misadvice concerning collateral
consequences in general and removal in particular can
never give rise to ineffective assistance. In short, the
considered and thus far unanimous view of the lower federal courts
charged with administering
Strickland clearly supports the
conclusion that that Kentucky Supreme Court’s position goes too
far.
In concluding that affirmative misadvice
regarding the removal consequences of a criminal conviction may
constitute ineffective assistance, I do not mean to suggest that
the Sixth Amendment does no more than require defense counsel to
avoid misinformation. When a criminal defense attorney is aware
that a client is an alien, the attorney should advise the client
that a criminal conviction may have adverse consequences under the
immigration laws and that the client should consult an immigration
specialist if the client wants advice on that subject. By putting
the client on notice of the danger of removal, such advice would
significantly reduce the chance that the client would plead guilty
under a mistaken premise.
III
In sum, a criminal defense
attorney should not be required to provide advice on immigration
law, a complex specialty that generally lies outside the scope of a
criminal defense attorney’s expertise. On the other hand, any
competent criminal defense attorney should appreciate the
extraordinary importance that the risk of removal might have in the
client’s determination whether to enter a guilty plea. Accordingly,
unreasonable and incorrect information concerning the risk of
removal can give rise to an ineffectiveness claim. In addition,
silence alone is not enough to satisfy counsel’s duty to assist the
client. Instead, an alien defendant’s Sixth Amendment right to
counsel is satisfied if defense counsel advises the client that a
conviction may have immigration consequences, that immigration law
is a specialized field, that the attorney is not an immigration
lawyer, and that the client should consult an immigration
specialist if the client wants advice on that subject.
Footnote 1
Citizens are not deportable, but “[q]uestions
of citizenship are not always simple.” ABA Guidebook §4.20, at 113
(explaining that U.S. citizenship conferred by blood is
“ ‘derivative,’ ” and that “[d]erivative citizenship
depends on a number of confusing factors, including whether the
citizen parent was the mother or father, the immigration laws in
effect at the time of the parents’ and/or defendant’s birth, and
the parents’ marital status”).
Footnote 2
“A disposition that is not a ‘conviction,’
under state law may still be a ‘conviction’ for immigration
purposes.”
Id., §4.32, at 117 (citing
Matter of
Salazar, 23 I. & N. Dec. 223, 231 (BIA 2002) (en
banc)). For example, state law may define the term “conviction” not
to include a deferred adjudication, but such an adjudication would
be deemed a conviction for purposes of federal immigration law. See
ABA Guidebook §4.37; accord, D. Kesselbrenner & L. Rosenberg,
Immigration Law and Crimes §2:1, p. 2–2 (2008) (hereinafter
Immigration Law and Crimes) (“A practitioner or respondent will not
even know whether the Department of Homeland Security (DHS) or the
Executive Office for Immigration Review (EOIR) will treat a
particular state disposition as a conviction for immigration
purposes. In fact, the [BIA] treats certain state criminal
dispositions as convictions even though the state treats the same
disposition as a dismissal”).
Footnote 3
See
United States v.
Kwan,
407 F. 3d 1005, 1015–1017 (CA9 2005);
United States v.
Couto, 311 F. 3d 179, 188 (CA2 2002);
Downs-Morgan v.
United States, 765 F. 2d 1534,
1540–1541 (CA11 1985) (limiting holding to the facts of the case);
see also
Santos-Sanchez v.
United States, 548 F.
3d 327, 333–334 (CA5 2008) (concluding that counsel’s advice was
not objectively unreasonable where counsel did not purport to
answer questions about immigration law, did not claim any expertise
in immigration law, and simply warned of “possible” deportation
consequence; use of the word “possible” was not an affirmative
misrepresentation, even though it could indicate that deportation
was not a certain consequence).
Footnote 4
See
Hill v.
Lockhart, 894
F. 2d 1009, 1010 (CA8 1990) (en banc) (“[T]he erroneous
parole-eligibility advice given to Mr. Hill was ineffective
assistance of counsel under
Strickland v. Washington”);
Sparks v
. Sowders, 852 F. 2d 882, 885 (CA6 1988)
(“[G]ross misadvice concerning parole eligibility can amount to
ineffective assistance of counsel”);
id., at 886 (Kennedy,
J., concurring) (“When the maximum possible exposure is overstated,
the defendant might well be influenced to accept a plea agreement
he would otherwise reject”);
Strader v.
Garrison,
611 F. 2d 61, 65 (CA4 1979) (“[T]hough parole eligibility
dates are collateral consequences of the entry of a guilty plea of
which a defendant need not be informed if he does not inquire, when
he is grossly misinformed about it by his lawyer, and relies upon
that misinformation, he is deprived of his constitutional right to
counsel”).
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