"R. v. Pham" involved an offender whose sentence would have made him ineligible to appeal his deportation if it were not reduced in length by one day. Neither the sentencing judge nor the offender's lawyers were aware of the potential immigration consequences at the time of sentencing. At the Supreme Court, Justice Wagner concluded that, had the sentencing judge been aware of the collateral consequences, he or she would have imposed a sentence that avoided them. He therefore reduced the length of the offender's sentence by one day.