People v. Douglas, No. 301546 (Mich. App. Apr. 12, 2012) (published)
The Michigan Court of Appeals found that a defendant was prejudiced when his attorney provided ineffective assistance at the plea stage because the attorney failed to properly advise him about the consequences of accepting a plea offer, namely, the proper maximums and minimums as charged versus the plea offer. This may help in Padilla cases in terms of showing prejudice when a defense attorney fails to properly advise of other consequences of accepting a plea offer, like removal.