If you have a dijit.Tree with an unlabelled root node, and then select (click-drag-release) multiple nodes, then you get a "Can't move focus to the control because it is invisible, not enabled, or of a type that does not accept the focus" error - but only in Internet Explorer. Here's an example (from the dojo book, with the minor difference that I removed the root label)
@import "http://o.aolcdn.com/dojo/1.1.0/dijit/themes/tundra/tundra.css";
