“Second Circuit Judge Robert Katzmann has again advanced the cause of effective assistance of counsel in deportation proceedings. Cerna v. United States is the second swallow this spring from federal courts. Just four weeks earlier Justice John Paul Stevens in a 7-2 decision, citing a lawyer’s neglect, reversed a criminal conviction, emphasizing the “severity of deportation”—“the equivalent of banishment or exile”. Padilla v. United States (March 31 2010).”