Dereje v. State, 837 N.W.2d 714

Dereje was convicted of fifth-degree criminal sexual conduct for groping S.J. in a taxi.
Parties proceeded to a trial on stipulated facts under Minn. R.Crim. P. 26.01, subd. 3, with Dereje waiving trial rights.
The court relied on S.J.’s version and some police reports to find Dereje guilty; fourth-degree charge was dropped.
Postconviction relief sought on grounds of invalid stipulated-facts procedure, ineffective counsel, and invalid waiver of trial rights.
Court of Appeals held the procedure did not constitute a stipulated-facts trial but found waiver converted proceedings to a bench trial; ineffective assistance found.
Supreme Court majority reverses, holds no valid 26.01(3) trial occurred but bench-trial procedure complied with 26.01(2) and counsel was not ineffective; remands to reinstate conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the trial a valid stipulated-facts trial?	Dereje argues the court did not conduct a 26.01(3) stipulated-facts trial.	Dereje contends the process violated the rule but limits waiver to 26.01(3) context.	Not a valid stipulated-facts trial.
Was there ineffective assistance of counsel?	Dereje contends counsel failed to subject case to adversarial testing.	Dereje argues counsel’s performance prejudiced outcome.	No structural error; but the court analyzes Strickland; majority finds no prejudice, reinstating conviction.
Did Dereje validly waive trial rights for a stipulated-facts trial?	Waiver was knowing and intelligent for a stipulated-facts path.	Waiver was not valid for the actual bench-trial conducted.	Waiver invalid for the actual proceedings; entitlement to new trial under waiver analysis.

State v. Dalbec, 800 N.W.2d 624 (Minn. 2011) (structural error and Strickland framework interplay; some counsel errors are not structural)
Bell v. Cone, 535 U.S. 685 (U.S. 2002) (counsel's performance not automatically structural error; forfeiture of closing argument not per se structural)
Florida v. Nixon, 543 U.S. 175 (U.S. 2004) (presumption that counsel acts within reasonable professional norms; strategic choices)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel (performance and prejudice))
Cronic, 466 U.S. 648 (U.S. 1984) (structural error when counsel entirely fails to subject the prosecution’s case to adversarial testing)
Missouri v. Frye, 132 S. Ct. 1399 (U.S. 2012) (plea bargaining can implicate ineffective assistance; pretrial negotiations matter)
Lafler v. Cooper, 132 S. Ct. 1376 (U.S. 2012) (advantageous plea offers and counsel’s performance affect outcomes)
U.S. v. Cronic, 466 U.S. 648 (U.S. 1984) (reiterates concept of structural error when adversarial testing is absent)
State v. Reese, 692 N.W.2d 741 (Minn. 2005) (credibility determination and cross-examination significance (cited in context))
State v. Jones, 392 N.W.2d 224 (Minn. 1986) (witness credibility testing and cross-examination importance)
State v. Hohenwald, 815 N.W.2d 823 (Minn. 2012) (rules of interpretation for criminal procedure)