Edited sentence: Collateral legal issues that might spring forth from the facts giving rise to the criminal charges are not within the domain of services envisioned by the 6th amendment.Criticism of Padilla stems from the fact that the Court has effectively created a duty upon criminal defense counsel to notify the defendant of a collateral issue.Generally, the 6th amendment requires counsel to only provide services related to the criminal charges he is facing.In that case, the Court established a strict duty of counsel to warn defendants at risk of deportation that a plea deal in which they admit guilt will likely result in removal from the United States.It is widely accepted that deportation/removal is a collateral issue not related to criminal charges.One glaring exception to this limitation in scope is found in the rule set forth in the U.Such collateral issues may include civil liability independent of criminal charges, other criminal charges sufficiently independent but loosely tied to the current crimes being defended, etc.Supreme Court's recent decision in Padilla v