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University of Iowa News Release


April 1, 2010

U.S. Supreme Court cites Iowa Law Review article in decision

For the second time this term, the United States Supreme Court has cited an article in the Iowa Law Review in one of its decisions.

The Court on Wednesday cited the Review's article in Padilla v. Kentucky, a case involving protection provided to criminal defendants by the Sixth Amendment. The citation was to the article "Ignorance Is Effectively Bliss: Collateral Consequences, Silence, and Misinformation in the Guilty-Plea Process," written by Syracuse University law professor Jenny Roberts, and published in 2009 in the Review.

In the article, Roberts argued that a criminal defendant's Sixth Amendment right to assistance of counsel requires that counsel must disclose "any serious consequences of guilty pleas." The Court generally agreed, holding in Padilla that the Sixth Amendment requires counsel to inform a criminal defendant that a guilty plea may result in deportation. The full article is available online at

The Court's opinion is online at

Earlier this term, the Court cited an Iowa Law Review article in its decision of Citizens United v. FEC. That decision is online at

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