IN RE YUNG-CHENG TSAI

Nos. 88770-5, 89992-4.

351 P.3d 138 (2015)

In the Matter of the Personal Restraint of YUNG-CHENG TSAI, Petitioner. In the Matter of the Personal Restraint of Muhammadou Jagana, Petitioner.

Supreme Court of Washington, En Banc.

Decided May 7, 2015.


Attorney(s) appearing for the Case

Eric J. Nielsen , Eric Broman, Nielsen Broman & Koch PLLC, Seattle, WA, for Petitioner.

Kathleen Proctor , Pierce County Prosecuting Atty. Ofc., Tacoma, WA, Ann Marie Summers , King County Prosecutor's Office, Seattle, WA, for Respondent.

Sarah A. Dunne , Attorney at Law, Nancy Lynn Talner , Attorney at Law, Shawn J. Larsen-Bright , Dorsey Whitney LLP, Seattle, WA, amicus counsel for American Civil Liberties Union of Washington.

Ann E. Benson , WA Defenders Assoc., Travis Stearns , Washington Appellate Project, Seattle, WA, amicus counsel for Washington Defender Association.

John Avrom Strait , Seattle University School of Law, Seattle, WA, Christopher N. Lasch , University of Denver Sturm College, Denver, CO, amicus counsel for Law Professors.

Pamela Beth Loginsky , Washington Assoc. of Prosecuting Atty., Olympia, WA, amicus counsel for Washington Association of Prosecuting Attorneys.

Matthew Hyrum Adams , Chris Stanislowski , NW Immigrants Rights Project, Seattle, WA, amicus counsel for Northwest Immigrant Rights Project.


¶ 1 As applied to Washington, the holding in Padilla v. Kentucky, 559 U.S. 356, 130 S.Ct. 1473, 176 L.Ed.2d 284 (2010) is an affirmation of an old rule of state constitutional law—the duty to provide effective assistance of counsel includes the duty to reasonably research and apply relevant...

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