On March 31, 2010, in Padilla v. Kentucky, 559 U.S. 356, 130 S. Ct. 1473 (2010), the Supreme Court held that the Sixth Amendment requires criminal defense counsel to advise a noncitizen defendant regarding the immigration consequences of a guilty plea, and, absent such advice, a noncitizen may raise a claim of ineffective assistance of counsel. On February 20, 2013, however, the Court held in Chaidez v. U.S., No. 11-820, slip. op. (February 20, 2013), that Padilla is a "new rule" that does not apply retroactively to Ms. Chaidez' case involving a federal conviction that was final before Padilla. This advisory will discuss claims for post-conviction relief that can still be asserted by immigrants who were not properly advised regarding the immigration consequences of a pre-Padilla criminal case.