We have cited Witta v. State. We cite the 6th District in our motion as well as PA S.C. ruling. We cite floriduh cases where plea agreements are considered contracts. We also argue Padilla. floriduh has said it would not retroactively apply Padilla, as it has “relied heavily for 22 years” on pre-existing legislation that adequately warned of the potential for deportation. They don’t dispute SCOTUS ruling in favor of Padilla; they simply say adequate warnings were in place during the time leading up to Padilla ruling. We raise the question, what warning did floriduh rely on for 22 years in warning of the civil SO consequences? Still waiting on Judge’s ruling.
Hope this helps you.