Therefore, we review this claim de novo. See State v. Edwards, 736 N.W.2d 334, 338 (Minn. App. 2007) (observing that this court review claims of ineffective assistance of counsel de novo), review denied (Minn. Sept. 26, 2007). II.

We review ineffective-assistance-of-counsel claims de novo. State v. Edwards, 736 N.W.2d 334, 338 (Minn.App. 2007), review denied (Minn. Sept. 26, 2007).

We review claims of ineffective assistance of counsel de novo. State v. Edwards, 736 N.W.2d 334, 338 (Minn.App. 2007), rev. denied (Minn. Sept. 26, 2007). The Strickland test requires a defendant to prove that (1) "counsel's representation fell below an objective standard of reasonableness," and (2) "there was a reasonable probability that, but for counsel's errors, the result of the proceeding would have been different."

8. We also decline to review the issues presented in Udoh's petitions for habeas corpus in district court. "Ordinarily, issues not briefed are waived." State v. Edwards, 736 N.W.2d 334, 340 (Minn.App. 2007), rev. denied (Minn. Sept. 26, 2007). Here, the brief Udoh submitted in this appeal makes no mention of the bases for relief presented in his habeas corpus petitions and provides no argument in support of them. Udoh has therefore forfeited consideration of these issues and we elect not to address their merits.

Given the nature of Parkinson's disease and its varied manifestations in different individuals—as even Mr. Young's own expert acknowledged—application of the Cronic presumption of prejudice is inappropriate here.See alsoState v. Edwards , 736 N.W.2d 334, 339 (Minn. Ct. App. 2007) (rejecting defendant's contention that "he was constructively denied counsel because his mentally ill attorney was equivalent to a sleeping attorney"); Johnson v. Norris , 207 F.3d 515, 517–18 (8th Cir. 2000) (declining to apply Cronic presumption when defense attorney was diagnosed with bipolar disorder and pointing out that there was "some question" whether attorney had the disorder at the time of trial). Nor was there a complete denial of the right to counsel.

We review ineffective-assistance-of-counsel arguments de novo. State v. Edwards, 736 N.W.2d 334, 338 (Minn. App. 2007), review denied (Minn. Sept. 26, 2007).

For example, the complete denial of counsel at a critical stage of a criminal proceeding is a structural error that warrants reversal "without inquiring into counsel's actual performance or requiring the defendant to show what effect counsel's representation had at trial." State v. Edwards, 736 N.W.2d 334, 338 (Minn. App. 2007) (citing United States v. Cronic, 466 U.S. 648, 659-62, 104 S. Ct. 2039, 2047-48 (1984)), review denied (Minn. Sept. 26, 2007).

We cannot conclude that counsel's unwillingness to raise objections during this brief portion of the trial was so antithetical to effective assistance of counsel that appellant is entitled to a presumption of prejudice. See State v. Edwards, 736 N.W.2d 334, 338 (Minn. App. 2007) (stating that "as a practical matter, it is difficult to imagine situations that would trigger structural error analysis beyond the failure on the part of counsel to inform a defendant of certain basic rights, such as the right to trial by jury, to self-representation, or to an appeal as a matter of right" (quotation omitted)), review denied (Minn. Sept. 26, 2007).

We review claims of ineffective assistance de novo. State v. Edwards, 736 N.W.2d 334, 338 (Minn.App. 2007), review denied (Minn. Sept. 26, 2007).