Task: Text Completion
Input (English): United States v. Reyes, 603 F.2d 69 (9th Cir.1979)). In contrast, other circuits have concluded strict compliance with the requirements of Rule 23(a) is necessary to waive a jury trial. E.g., United States v. Garrett, 727 F.2d 1003, 1012 (5th Cir.1984), aff'd, 471 U.S. 773, 105 S.Ct. 2407, 85 L.Ed.2d 764 (1985). Mindful of Rule 23(a)’s writing requirement and the reasons for it, we conclude requiring strict compliance with Rule 23(a) is not justified. In those circumstances where the record clearly reflects a defendant’s waiver of the right is voluntary, knowing, and intelligent, we see no practical justification for finding a waiver invalid simply because Rule 23(a)’s writing requirement has not been met. Cf. United States v. Prichard, 875 F.2d 789, 790 (10th Cir.1989) (per curiam) (<HOLDING>). The Constitution requires only that a waiver 
 Holding statements: (A) holding that technical violations of fedrcrimp 41 d require suppression if there was a deliberate disregard of the rule or if the defendant was prejudiced (B) holding that it is error to conduct most of the jury selection process in the absence of the defendant (C) holding that the validity of a collateral waiver is a threshold issue (D) holding that a failure to file an appeal is within the scope of the waiver because the failure does not undermine the validity of the plea or waiver (E) holding that collateral review of the validity of a jury waiver in the absence of a rule 23a writing is not available absent any indication the defendant was prejudiced by the technical error
Output (English): (E)