In Martinez-Hernandez v. Holder, the Ninth Circuit affirmed the Board of Immigration Appeals' denial of a motion to reopen based on ineffective assistance of counsel. Martinez-Hernandez alleged that his prior counsel should have disputed an Immigration Judge's assertion that his criminal conviction barred him from applying for cancellation of removal for non-lawful permanent residents. Although he had a lawful permanent resident mother and U.S.-citizen child, Martinez-Hernandez provided no evidence that either of them would suffer the requisite hardship to make him eligible for cancellation. In affirming the Board's decisions, the Ninth Circuit noted that the existence of a qualifying relative is not enough to demonstrate that it is plausible that Martinez-Hernandez was eligible for the relief he sought, and thus, he could not establish any prejudice stemming from his prior counsel's actions.
The full text of the decision can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2015/02/24/11-70492.pdf