In Chaidez v. United States, 133 S.Ct. 1103 (Feb. 20, 2013), the court stated:

True enough, three federal circuits (and a handful of state courts) held before Padilla that misstatements about deportation could support an ineffective assistance claim. But those decisions reasoned only that a lawyer may not affirmatively misrepresent his expertise or otherwise actively mislead his client on any important matter, however related to a criminal prosecution. See, e.g., United States v. Kwan, 407 F.3d 1005, 1015"1017 (C.A.9 2005). They co-existed happily with precedent, from the same jurisdictions (and almost all others), holding that deportation is not so unique as to warrant an exception to the general rule that a defendant need not be advised of the [collateral] consequences of a guilty plea. United States v. Campbell, 778 F.2d 764, 769 (C.A.11 1985).FN14 So at most, Chaidez has shown that a minority of courts recognized a separate rule for material misrepresentations, regardless whether they concerned deportation or another collateral matter. That limited rule does not apply to Chaidez's case. And because it lived in harmony with the exclusion of claims like hers from the Sixth Amendment, it does not establish what she needs to"that all reasonable judges, prior to Padilla, thought they were living in a Padilla-like world.

. . .

Nor, finally, does St. Cyr have any relevance here. That decision stated what is common sense (and what we again recognized in Padilla ): A reasonably competent lawyer will tell a non-citizen client about a guilty plea's deportation consequences because [p]reserving the client's right to remain in the United States may be more important to the client than any potential jail sentence. Padilla, 559 U.S., at """", 130 S.Ct., at 1483 (quoting St. Cyr, 533 U.S., at 322, 121 S.Ct. 2271). But in saying that much, St. Cyr did not determine that the Sixth Amendment requires a lawyer to provide such information.

(Chaidez, supra, at ___.)