In Re Pers. Restraint of Yung-Cheng Tsai (Majority and Dissent)
Annotate this CaseAs applied to Washington, the holding in "Padilla v. Kentucky," (559 U.S. 356 (2010) was an affirmation of the duty to provide effective assistance of counsel, which included the duty to reasonably research and apply relevant statutes. However, language in certain Washington appellate cases made it appear that this rule did not apply to RCW 10.40.200. "Padilla" superseded those cases, significantly changing state law. Muhammadou Jagana raised a claim that would have been rejected before "Padilla" based on those superseded appellate cases. The Washington Supreme Court therefore reversed the Court of Appeals' order dismissing Jagana's personal restraint petition (PRP) and remanded to the trial court for an evidentiary hearing. However, Yung-Cheng Tsai's claim was available before "Padilla," and Tsai did in fact raise his claim with the assistance of an attorney in 2008. That motion was denied based on an issue of law not affected by Padilla, and Tsai did not appeal. The Court therefore affirmed the Court of Appeals' order dismissing Tsai's PRP.
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