Deportation: A penal or collateral consequence?

In this article the issue before the Court is whether the Sixth Amendment requires a lawyer to advise clients of the deportation ‎consequences of a guilty plea. The Court has not rendered a decision yet, so right now it is only as a collateral consequence. Therefore there is no Sixth Amendment duty to give this advice. The Court may change directions.

Practically speaking, the New Jersey Plea Form covers this point in Question 17. The client reviews this form with his lawyer, signs it before entering the guilty plea, and the judge admits this evidence during plea hearings. So in New Jersey it seems that unless a lawyer completely skips ‎this question, it should be less of a concern.‎