Upon some further research, it looks like this bug is similar: 
https://bugs.launchpad.net/ubuntu/+source/grub2/+bug/1848892
However, that bug seems to happen all the time where as for me it's 
intermittent.

I tried the workaround from the linked bug and can confirm that when I 
experience the issue I can boot successfully by:
* 'c'
* grub> rmmod tpm
* 'esc'
* 'enter' to select normal boot menu entry.

** Description changed:

  Sometimes on reboots and quick cold boots (poweroff then hit power
  immediately) I get
  
  ```
  error: Command failed. -repeated a number of times then
  error: you need to load the kernel first.
  
  Press any key to continue...
  ```
  
- * cold booting usually fixes this and I'm able to reboot normally.
+ * cold booting usually fixes this and I'm able to boot normally.
  * I have three identical laptops and have seen the issue on 2 (i've only 
installed 20.04 on two).
  * I don't see the problem on 18.04.
  * If I go into the grub> menu many commands fail "true" "cat" but some don't 
"ls" "false."
  
  The source for grub points to tpm.c when I search for "Command failed."
  I also notice that there's no such file in 2.02 version of grub so maybe
  that's related to why it doesn't work.
  
  I haven't been able to find a combination of BIOS settings that
  mitigates this. I have tried disabling everything I could think of.
  
  This laptop has Intel PTT which I think is baked into the BIOS (which I
  upgraded to the newest).
  
  I will have these laptops for some time but won't be able to test much
  beyond a week or two.
  
  ProblemType: Bug
  DistroRelease: Ubuntu 20.04
  Package: grub2-common 2.04-1ubuntu26
  ProcVersionSignature: Ubuntu 5.4.0-37.41-generic 5.4.41
  Uname: Linux 5.4.0-37-generic x86_64
  ApportVersion: 2.20.11-0ubuntu27.2
  Architecture: amd64
  CasperMD5CheckResult: skip
  CurrentDesktop: ubuntu:GNOME
  Date: Tue Jun 16 16:33:42 2020
  InstallationDate: Installed on 2020-06-08 (8 days ago)
  InstallationMedia: Ubuntu 20.04 LTS "Focal Fossa" - Release amd64 (20200423)
  ProcEnviron:
-  PATH=(custom, no user)
-  XDG_RUNTIME_DIR=<set>
-  LANG=en_US.UTF-8
-  SHELL=/bin/bash
+  PATH=(custom, no user)
+  XDG_RUNTIME_DIR=<set>
+  LANG=en_US.UTF-8
+  SHELL=/bin/bash
  SourcePackage: grub2
  UpgradeStatus: No upgrade log present (probably fresh install)

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https://bugs.launchpad.net/bugs/1883785

Title:
  intermittent boot failure dell inspiron 3593

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