State v. Guaman, 162 A.3d 727

Defendant Manuel A. Guaman (Ecuadorian citizen) was charged with first‑degree assault after severely injuring a victim with a broken bottle; conviction carried virtually certain deportation under federal law.
Defendant initially retained Attorney David Feliu, who discussed immigration consequences and gave an immigration attorney referral; defendant later retained Attorney Ira Mayo.
Mayo represented defendant through the plea period, informed him of a plea offer, and later began a four‑month suspension from the practice of law (which Mayo disclosed before the plea hearing).
On September 19, 2014, under the Alford doctrine, defendant entered a guilty plea to first‑degree assault after a canvass in which he acknowledged understanding immigration consequences and that he had discussed them with counsel; court accepted the plea.
Defendant later moved to withdraw his plea, alleging ineffective assistance: (1) counsel failed to advise him of immigration consequences; and (2) counsel had an undisclosed/conflicting interest because of his impending suspension. After a multi‑day evidentiary hearing the trial court credited Mayo’s testimony and denied the motion.
On appeal, the Appellate Court affirmed, finding (based on credibility findings) that Mayo did advise the defendant about deportation and that any adverse effect from Mayo’s suspension was speculative, so no ineffective assistance or actual conflict was shown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel failed to advise of immigration consequences in violation of Padilla	State: plea canvass and record show defendant was informed; counsel satisfied duty	Guaman: Mayo did not tell him about deportation and never discussed immigration; therefore counsel ineffective	Court: Credited Mayo’s testimony that he repeatedly advised defendant of deportation; no deficient performance; motion denied
Whether counsel labored under an actual conflict of interest that impaired advice due to impending suspension	State: suspension disclosure and offered alternatives meant no adverse effect or conflict	Guaman: Mayo’s forthcoming four‑month suspension limited his ability to fully explain options and created a conflict, warranting presumed prejudice	Court: No specific factual finding of an actual conflict; any impact of suspension was speculative; defendant failed to show adverse effect; motion denied

Padilla v. Kentucky, 559 U.S. 356 (2010) (counsel must advise noncitizen clients about immigration consequences of guilty pleas)
Budziszewski v. Commissioner of Correction, 322 Conn. 504 (2016) (interpreting Padilla; counsel must convey severity of immigration consequences in understandable terms)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong test for ineffective assistance of counsel)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for ineffective assistance claims arising from guilty pleas)
North Carolina v. Alford, 400 U.S. 25 (1970) (guilty plea may be entered while maintaining a claim of innocence)
State v. Anthony D., 320 Conn. 842 (2016) (standard of review and strictness for motions to withdraw guilty pleas)