What is the test for a motion to challenge a guilty plea under Rule 11 of the Immigration Code?

Rule 11 "is designed to ensure that a defendant's plea of guilty is a voluntary and intelligent choice among the alternative courses of action open to the defendant," Zhang v. United States, 506 F.3d 162, 168 (2d Cir. 2007), and our precedent requires "strict adherence," United States v. Pattee, 820 F.3d 496, 503 (2d Cir. 2016). Nonetheless, all that is required is that a defendant be placed on notice that his guilty plea has potential immigration consequences and that he be provided an opportunity to discuss those consequences more fully with his attorney or with an immigration specialist. Zhang, 506 F.3d at 169. As we noted in Zhang:

Id. at 169.

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Where a Rule 11 challenge is brought in a motion under 18 U.S.C. 2255, the "movant can successfully challenge [the] guilty plea conviction . . . only by establishing that the violation constituted a constitutional or jurisdictional error, or by showing that the error resulted in a complete miscarriage of justice or in a proceeding inconsistent with the rudimentary demands of fair procedure." Lucas v. United States, 963 F.2d 8, 12-13 (2d Cir. 1992) (internal quotations and citations omitted). The movant must also show prejudice, meaning that "he did not understand the consequences of his plea, or that, if he had been properly advised, he would not have pled guilty." Id. at 13.