Neufville v. State, 13 A.3d 607

Neufville pled nolo contendere in May 2004 to assault with intent to rob, felony assault (two counts), and firearms offenses; parallel pleas to breaking and entering and July 2003 assault.
Sentences totaled 20 years' imprisonment with 3.5 years to serve on February 2003 offenses and 16 years with 2 years to serve on July 2003 offenses; sentences run concurrently.
In May 2005, Neufville sought postconviction relief alleging ineffective assistance of trial counsel, including failure to investigate, interview witnesses, file motions, or prepare adequately, and failure to explain immigration consequences.
Neufville, born in Liberia, argued his immigration status and potential deportation were affected by the pleas and counsel’s advice.
The Superior Court denied relief after hearing both sides; Neufville appealed to the Rhode Island Supreme Court.
The Supreme Court affirmed, holding no reversible error in counsel’s performance or in the immigration advice under Padilla and Rhode Island statutes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel’s performance was deficient under Strickland.	Neufville asserts failure to investigate/prep and interview witnesses.	State contends counsel acted within the reasonable range under totality of circumstances.	No deficient performance; within permissible range.
Whether trial counsel failed to advise on immigration consequences under Padilla.	Counsel did not adequately inform about deportation risk.	Defendant knew of possible deportation; plea form warned of consequences.	Adequate immigration guidance given; Padilla not violated.
Whether Neufville was prejudiced by counsel’s performance in a plea context.	But-for counsel, would have gone to trial and obtained a better outcome.	Pleas carried shorter sentence; prejudice unlikely in negotiated plea.	No prejudice established; plea outcome not worse than trial risk.

Strickland v. Washington, 466 U.S. 668 (Supreme Court, 1984) (establishes two-prong deficient performance and prejudice test)
Rodrigues v. State, 985 A.2d 311 (R.I. 2009) (deference to factual findings; ineffective assistance standard)
Moniz v. State, 933 A.2d 691 (R.I. 2007) (totality of the circumstances; strong presumption of competence)
Hazard v. State, 968 A.2d 886 (R.I. 2009) (deference to trial court credibility; scope of investigation)
Hill v. Lockhart, 474 U.S. 52 (Supreme Court, 1985) (prejudice standard in plea negotiations)
Figueroa v. State, 639 A.2d 495 (R.I. 1994) (plea-related prejudice standard in Rhode Island)