Cited by

“Certain counsel-related errors, however, may be structural errors, which do not require a showing of prejudice.”

“Structural error consists of defects in the constitution of the trial mechanism, which defy analysis by harmless-error standards because the entire conduct of the trial from beginning to end is obviously affected.” (quotation omitted).

“Structural error consists of defects in the constitution of the trial mechanism, which defy analysis by harmless-error standards because the entire conduct of the trial from beginning to end is obviously affected.”

Under this structural error analysis, the case “must involve a complete failure by counsel.” State v. Dalbec , (quotation omitted).

When an error does implicate a constitutional right, appellate courts “will award a new trial unless the error is harmless beyond a reasonable doubt.” Davis, d at 533.4 We need not determine whether the error here was constitutional in is obviously affected.” State v. Dalbec , (quotation omitted).

Structural errors are “defects in the c onstitution of the trial mechanism, which defy analysis by ‘harmless-error’ standards beca use the entire conduct of the trial from beginning to end is obviously affected.” State v. Dalbec , (quotation omitted).

State v. Dalbec , (quoting Arizona v. Fulminante , 499 U.S. 279, 309–10, 111 S. Ct. 1246, 1265 (1991)).

6 In his memorandum, Zumberge categorizes these errors as “structural errors.” But structural errors are “defects in the constitution of the trial mechanism, which defy analysis by harmless-error standards because the entire conduct of the trial from beginning to end is obviously affected.” (Mi nn.

See State v. Dalbec , , 629 (Minn. 2011) (remanding to the court of appeals for consideration of the arguments that were raised but not decided in the court of *642 appeals); see also Rochester City Lines Co. v. City of Rochester , , 448 (Minn. 2018) (explaining that when alternative issues are raised but not decided in the

at 310, 111 S. Ct. at 1265; State 7 v. Dalbec

7 Counsel’s conduct in this case is close to a failure to subject the probation- revocation proceeding to “ meaningful adversarial testing.” (quoting United States v. Cronic, 466 U.S. 648, 659, 104 S. Ct. 2039, 2047 (1984)).

at 697-98, 122 S. Ct. at 1851-52

“Certain counsel-related errors, however, may be structural errors, which do not require a showing of prejudice.”

E. 31.02 (providing for plain error review); (evaluating whether an error committed in the course of a bench trial constituted structural error and instead treating the error as a trial error).

“Trial counsel’s performance is presumed to be reasonable,” and “a party claiming ineffective assistance of counsel must prove both deficient performance and prejudice,”

“Ineffective-assistanee-of-counsel claims are generally analyzed as trial errors under Strickland v. Washington.”

“Because it is presumed that the lawyer is competent to provide the guiding hand that the defendant needs, the burden rests on the accused to demonstrate a constitutional violation.” (quotation omitted).

See, (holding that defense counsel’s failure to submit written closing argument, as defense counsel and the State had agreed to do, was not structural error); , 251 n. 6 (Minn.2010) (holding that error in continuing trial in the defendant’s absence was not structural error