On April 11, 2012, IDP and the National Immigration Project of the National Lawyers Guild issued a practice advisory addressing the argument that the U.S. Supreme Court Lafler v. Cooper decision supports the retroactive application of Padilla. The advisory also explains how the U.S. Supreme Court Missouri v. Frye decision supports the argument that a court warning cannot cure the prejudice flowing from a Padilla violation. Additionally, the advisory details how an advocate can use Missouri v. Frye and the U.S. Supreme Court Vartelas v. Holder decision to assert that the scope of defense counsel’s duty under Padilla extends to seeking a reasonable resolution that mitigates or avoids immigration consequences. Lastly, the advisory shows how to use Missouri v. Frye to argue that the defendant suffered prejudice under Padilla from the loss of the opportunity to seek a reasonable resolution that would have mitigated or eliminated the immigration consequences. For a copy of this advisory, click here. For additional research and technical information on post-conviction relief claims under Padilla, click here.