United States v. Fazio, 795 F.3d 421 (3d Cir. Aug. 4, 2015) (defendant could not establish ineffective assistance of counsel for failure to warn of immigration consequences where warning of potential of immigration consequences by District Court in plea colloquy and standard language in plea agreement cured any possible error counsel may have made).

Note: The district court asked the defendant Do you understand that no one, including your attorney or me or the government's attorney can predict to a certainty the effect of your conviction on your immigration status? The plea agreement included similar may cause deportation, language, and defense counsel admitted did no legal research at all, while later retained immigration counsel identified deportation as a certainty. This claim was defeated at the district court level, due to the possibility of someone in a similar situation getting an S-Visa or Congress changing the law. This case seems to almost entirely ignore the holding (or underlying facts of) Padilla, even though citing it once or twice.