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State v. Toshniyazov — Twelfth District reverses denial of plea withdrawal, requires Strickland analysis for noncitizen’s IAC claim

The Twelfth District reversed the trial court’s denial of a noncitizen defendant’s motion to withdraw his no-contest plea, holding that the court was required to apply the Strickland two-prong test when the motion was premised on counsel’s failure to advise of immigration consequences under Padilla v. Kentucky.

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