Cun-Lara v. State, 126 Hawai'i 541 (Hawaii App. March 28, 2012) (defense counsel's failure to advise defendant of exact immigration consequences, instead advising that "defendant would be lucky if he was not deported" for the offense if he plead to charge of possessing drug paraphernalia, did not constitute deficient performance, as required to support claim of ineffective assistance of counsel, because deportation consequences of defendant's plea were not truly clear; instead, defendant appeared to remain eligible for cancellation of removal from country, as his paraphernalia conviction did not appear to constitute an aggravated drug felony under federal law, defendant had lived for more than ten years in State, and he did not claim to have been unlawfully admitted for permanent residence for at least five years).

NOTE: The obvious flaw in the reasoning behind this decision is that the court conflates a finding of deportability with availability of relief, and concludes that the availability of relief makes the immigration consequences of the plea unclear.