Chaidez v. United States - SCOTUS
Padilla v. Kentucky, 130 S.Ct. 1473 (2010)—holding that defense counsel can render ineffective assistance of counsel for failing to adequately admonish a defendant of the immigration consequences of his guilty plea— does not apply retroactively to cases already final on appeal. Padilla broke new ground by changing the law in most jurisdictions; thus, it “developed” new law. Under Teague v. Lane, 109 S.Ct. 1060 (1989) a new law does not apply to convictions already final on direct appeal.