United States v. Karnail Singh, 95 F.4th 1028

Karnail Singh entered the U.S. illegally, sought asylum twice using different identities, was denied asylum, but later married a U.S. citizen and obtained permanent residency and naturalization under false pretenses.
Singh later acquired a U.S. passport and denied having used aliases or false information when questioned by border officials.
Upon discovery of his deceit, Singh was charged with using a fraudulently procured passport and making false statements to immigration officials; he pled guilty to the passport charge as part of a plea bargain.
The plea agreement acknowledged possible immigration consequences, but Singh contended he believed his citizenship was only at risk if he committed another crime.
After the government sought to revoke his citizenship, Singh petitioned for a writ of coram nobis to set aside his conviction, arguing his plea was uninformed and his counsel was ineffective; the district court denied relief.
On appeal, Singh challenged the validity of his plea, the adequacy of Rule 11 warnings, the effectiveness of counsel, and the lack of a hearing on his petition.

Issue	Singh's Argument	Government's Argument	Held
Due Process – Knowing Plea	Misunderstood plea’s effect on citizenship due to misleading advice.	Collateral immigration consequences do not affect validity of plea.	No due process violation.
Rule 11 Immigration Warning	District court’s warning was inadequate and ambiguous; plea agreement misleading.	Generic warning sufficed under Rule 11; court not required to correct misunderstandings.	Court met Rule 11 requirements.
Ineffective Assistance of Counsel	Counsel wrongly advised plea wouldn’t risk citizenship; would have gone to trial.	Evidence shows Singh pled regardless of immigration risk; court gave warning.	No prejudice; ineffective assistance rejected.
Necessity of Coram Nobis Hearing	Should have had an evidentiary hearing before denial.	Record shows no entitlement to relief, making a hearing unnecessary.	No hearing was required.

United States v. Morgan, 346 U.S. 502 (defines coram nobis as an extraordinary remedy for fundamental errors)
McCarthy v. United States, 394 U.S. 459 (guilty pleas must be knowing for due process)
Strickland v. Washington, 466 U.S. 668 (establishes ineffective assistance of counsel standard)
Hill v. Lockhart, 474 U.S. 52 (ineffective counsel claim in plea context)
Padilla v. Kentucky, 559 U.S. 356 (immigration consequences of criminal convictions are complex)