UNITED STATES OF AMERICA v. ELANO SERRANO ZUNIGA
The Ninth Circuit vacated a conviction for illegal reentry, holding that ineffective assistance of counsel can functionally deprive a defendant of meaningful judicial review under 8 U.S.C. § 1326(d). The court reversed the denial of a motion to dismiss the indictment because the defendant's counsel failed to pursue the only form of relief legally available to him.