Rulings regarding deportation were superseded by "Padilla v. Kentucky" in 2010. "... counsel must inform her client whether his plea carries a risk of deportation." The United States Supreme Court held that the collateral consequence of deportation was a consequence of such great importance that failure by counsel to advise the defendant of deportation is ineffective assistance of counsel which is a constitutional protection under the Sixth Amendment. After "Padilla", there has been significant litigation in the lower courts about whether attorneys are required to advise their criminal clients about other consequences of convictions.