The Sixth Circuit has determined that the Sixth Amendment does not require criminal defense counsel to advise a naturalized U.S. citizen that a guilty plea may create a risk of later civil denaturalization and removal. The petitioner, a naturalized citizen, argued that his guilty plea was constitutionally defective because his attorney failed to warn him that the conviction could later be used in denaturalization proceedings.
The Court rejected that argument, holding that denaturalization is a collateral civil consequence of a conviction, not a direct criminal penalty. The Court distinguished Padilla, explaining that deportation following a criminal conviction is uniquely intertwined with the criminal process, while denaturalization generally requires a separate civil proceeding and is not automatic. The Court therefore affirmed the denial of coram nobis relief.
The full text of United States v. Singh can be found here: https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0130p-06.pdf