Cited by

(stating that appellate courts “need not analyze both elements of the Strickland test if one or the other is determinative”).

“When the immigration consequences of a guilty plea are ‘truly clear,’ defense counsel must affirmatively advise a defendant that the plea will ‘subject [the defendant] to automatic deportation.’” (quoting Padilla, 559 U.S. at 360, 369).

d 716, 720 (Minn. 2017).

“We need not analyze both elements of the Strickland test if one or the other is determinative.”

See, -26 (Minn. 2017) (analyzing ineffective-assistance-of-counsel claim related to advising client about immigration consequences for pleading guilty to an offense classified at a certain felony level) .

d 716, 719-20 (Minn. 2017).

To withdraw a plea due to ineffective assistance of counsel, the postconviction court must determine “(1) that plea counsel’s representation ‘fell below an objective standard of reasonableness,’ and (2) ‘that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.’” (quoting Strickland v. Washington, 466 U.S. 668, 687-88, 694 (1984)).

3 ( noting that , in the context of an ineffective-assistance-of-counsel claim, only when “conviction of the charged offense clearly subjects the defendant to removal from the United States[, does] the attorney [have] a constitutional obligation t o advise the defendant of this fact before he or sh

Trott, d at 252; see Lussier, d at 589; aff’d on other grounds

(applying and explaining Padilla).

(“In effective assistance of counsel renders a guilty plea involuntar y and unintelligent.”), aff’d

See State v. Trott , see also Sanchez v. State , aff’d on other grounds , ).

Sanchez v. State , aff’d, see also State v. Hoaglund , n.9 (1976) (permitting use of whole record, including presentence investigation report ).

Sanchez v. State , –20 (Minn. 2017).

A complaint “may provide a factual basis for a defendant’s plea,” and a reviewing court is “permitted to examine the complaint to assess whether a defendant’s plea was accurate.” (citation omitted), aff’d

First, “[t]he complaint may provide a factual basis for a defendant’s plea, and we are permitted to examine the complaint to assess whether a defendant’s plea was accurate.” aff’d

Sanchez v. State , -20 (Minn .

A court “need not analyze bo th elements of the Strickland test if one or the other is determinative.”

A complaint “may provide a factual basis for a defendant’s plea, and we are permitted to examine the complaint to assess whether a defendant’s plea was accurate.” (citation omitted), aff’d

.” (“A motion to withdraw a plea after sentencing must be raised in a postconviction petition.”), aff’d

“We review findings of fact for clear error and issues of law de novo.”

Immigration and Customs 1 DACA is “a program under which noncitizens who come to the United States as children can receive a limited deferral from removal proceedings.” d 716, 718 (Minn. 2017).

“The complaint may provide a factual basis for a defendant’s plea, and [reviewing courts] are permitted to examine the complaint to assess whether a defendant’s plea was accurate.” aff’d

“The complaint may provide a factual basis for a defendant’s plea, and [reviewing courts] are permitted to examine the complaint to assess whether a defendant’s plea was accurate.” Sanchez v. State , aff’d