Continuing the inevitable development of right-to-counsel case law in the states courts, the Washington Supreme Court held last week that the U.S. Supreme Court’s landmark opinion in Padilla v. Kentucky, 559 U.S. 356 (2010), applies no matter when the conviction was entered. In re Tsai, No. 88770-5, slip op. (Wash. May 7, 2005). A divided Washington Supreme Court—five justices in the majority, four in dissent—concluded that Padilla was not a new rule of constitutional law, thus it applies retroactively. This case involved two separate claims that were consolidated at the state supreme court [...]