In Vega v. Ryan, ___ F.3d ___, 2014 WL 2019294 (9th Cir. May 19, 2014), superseding opinion, 735 F.3d 1093 (9th Cir. Nov. 13, 2013), the Ninth Circuit held that defense counsels duty to investigate is not diminished by the fact that the defendant himself may already be aware of the information. This decision has an important application to a claim of ineffective assistance of counsel for failure to investigate the defendants immigration status, which led to the Padilla errors of failure to advice or mistaken advice to the client concerning immigration consequences of the plea. Immigration consequences are pervasive; 20% or more of all defendants are non-citizens, who may suffer them. The fact that the defendant may be aware of his or her immigration status does not excuse counsels failure to investigate the immigration status, since immigrants may very well misunderstand the significance of their immigration status to the criminal case, and vice versa.