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183 Idaho opinions name it 2 courts 1987–2026 52 in the last five years
The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Adamcikgreen2 sentences2026State v. Adamcik, 152 Idaho 445, 483 , 272 P.3d 417, 455 (2012). 2026State v. Adamcik, 152 Idaho 445, 483 , 272 P.3d 417, 455 (2012). | 60 | 62 |
State v. Perrygreen2 sentences2026“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Perry, 150 Idaho 209, 230 , 245 P.3d 961, 982 (2010). 2026“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Perry, 150 Idaho 209, 230 , 245 P.3d 961, 982 (2010). | 25 | 45 |
State v. Mooregreen2 sentences2020“The presence of errors, however, does not by itself require the reversal of a conviction, since under due process a defendant is entitled to a fair trial, not an error-free trial.” Id. (quoting State v. Moore, 131 Idaho 814, 823, 965 P.2d 174, 18 183 (1998)). “[A]lleged errors at trial[ ] that are not followed by a contemporaneous objection[ ] will not be considered under the cumulative error doctrine unless said errors are found to pass the threshold analysis under our fundamental error doctrine.” Perry, 150 Idaho at 230, 245 P.3d at 982. 2020“The presence of errors, however, does not by itself require the reversal of a conviction, since under due process a defendant is entitled to a fair trial, not an error-free trial.” Id. (quoting State v. Moore, 131 Idaho 814, 823, 965 P.2d 174, 18 183 (1998)). “[A]lleged errors at trial[ ] that are not followed by a contemporaneous objection[ ] will not be considered under the cumulative error doctrine unless said errors are found to pass the threshold analysis under our fundamental error doctrine.” Perry, 150 Idaho at 230, 245 P.3d at 982. | 24 | 32 |
State v. Martinezgreen2 sentences2025“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Perry, 150 Idaho 209, 230 , 245 P.3d 961, 982 (2010) (citing State v. Martinez, 125 Idaho 445, 453 , 872 P.2d 708, 716 (1994)). 2025“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Perry, 150 Idaho 209, 230 , 245 P.3d 961, 982 (2010) (citing State v. Martinez, 125 Idaho 445, 453 , 872 P.2d 708, 716 (1994)). | 13 | 15 |
State v. Campbellgreen2 sentences2018While this Court has recognized the doctrine of cumulative error, State v. Larsen, 123 Idaho 456, 459 , 849 P.2d 129, 132 (Ct. App. 1993) and State v. Campbell, 104 Idaho 705, 719 , 662 P.2d 1149, 1163 (Ct. App. 1983), a necessary predicate to the application of the doctrine is a finding of error in the first instance. 2018While this Court has recognized the doctrine of cumulative error, State v. Larsen, 123 Idaho 456, 459 , 849 P.2d 129, 132 (Ct. App. 1993) and State v. Campbell, 104 Idaho 705, 719 , 662 P.2d 1149, 1163 (Ct. App. 1983), a necessary predicate to the application of the doctrine is a finding of error in the first instance. | 11 | 14 |
State v. Fieldgreen2 sentences2018As a result, "the cumulative error doctrine requires reversal of a conviction when there is 'an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, the errors show the absence of a fair trial, in contravention of the defendant's constitutional right to due process.' " State v. Field , 144 Idaho 559 , 572-73, 165 P.3d 273 , 286-87 (2007) (quoting State v. Moore , 131 Idaho 814 , 823, 965 P.2d 174 , 183 (1998) ). 2018As a result, "the cumulative error doctrine requires reversal of a conviction when there is 'an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, the errors show the absence of a fair trial, in contravention of the defendant's constitutional right to due process.' " State v. Field , 144 Idaho 559 , 572-73, 165 P.3d 273 , 286-87 (2007) (quoting State v. Moore , 131 Idaho 814 , 823, 965 P.2d 174 , 183 (1998) ). | 7 | 10 |
State v. Hawkinsgreen2 sentences2025“However, a necessary predicate to the application of the doctrine is a finding of more than one error.” Id. (citing State v. Hawkins, 131 Idaho 396, 407 , 958 P.2d 22, 33 (Ct. App. 1998)). 2025“However, a necessary predicate to the application of the doctrine is a finding of more than one error.” Id. (citing State v. Hawkins, 131 Idaho 396, 407 , 958 P.2d 22, 33 (Ct. App. 1998)). | 7 | 8 |
State v. Larsengreen2 sentences2018While this Court has recognized the doctrine of cumulative error, State v. Larsen, 123 Idaho 456, 459 , 849 P.2d 129, 132 (Ct. App. 1993) and State v. Campbell, 104 Idaho 705, 719 , 662 P.2d 1149, 1163 (Ct. App. 1983), a necessary predicate to the application of the doctrine is a finding of error in the first instance. 2018While this Court has recognized the doctrine of cumulative error, State v. Larsen, 123 Idaho 456, 459 , 849 P.2d 129, 132 (Ct. App. 1993) and State v. Campbell, 104 Idaho 705, 719 , 662 P.2d 1149, 1163 (Ct. App. 1983), a necessary predicate to the application of the doctrine is a finding of error in the first instance. | 7 | 7 |
State v. Seversongreen2 sentences2015“Under the cumulative error doctrine, ‘an accumulation of irregularities, each of which might be harmless in itself, may in the aggregate reveal the absence of a fair trial in contravention of the defendant’s right to due process.’ ” State v. Shackelford, 150 Idaho 355, 385 , 247 P.3d 582, 612 (2010) (quoting State v. Severson, 147 Idaho 694, 723 , 215 P.3d 414, 443 (2009)). “[A] necessary predicate to the application of the doctrine is a finding of more than one error.” State v. Perry, 150 Idaho 209, 230 , 245 P.3d 961, 982 (2010). 2015“Under the cumulative error doctrine, ‘an accumulation of irregularities, each of which might be harmless in itself, may in the aggregate reveal the absence of a fair trial in contravention of the defendant’s right to due process.’ ” State v. Shackelford, 150 Idaho 355, 385 , 247 P.3d 582, 612 (2010) (quoting State v. Severson, 147 Idaho 694, 723 , 215 P.3d 414, 443 (2009)). “[A] necessary predicate to the application of the doctrine is a finding of more than one error.” State v. Perry, 150 Idaho 209, 230 , 245 P.3d 961, 982 (2010). | 6 | 9 |
State v. Peitegreen2 sentences2015“The cumulative error doctrine ‘refers to an accumulation of irregularities, each by itself might be harmless, but when aggregated, the errors show the absence of a fair trial, in contravention of the defendant’s constitutional right to due process.’” State v. Moore, 131 Idaho 814, 823 , 965 P.2d 174, 183 (1998) (quoting State v. Peite, 122 Idaho 809, 822 , 839 P.2d 1223, 1236 (Ct. App. 1992)). 2015“The cumulative error doctrine ‘refers to an accumulation of irregularities, each by itself might be harmless, but when aggregated, the errors show the absence of a fair trial, in contravention of the defendant’s constitutional right to due process.’” State v. Moore, 131 Idaho 814, 823 , 965 P.2d 174, 183 (1998) (quoting State v. Peite, 122 Idaho 809, 822 , 839 P.2d 1223, 1236 (Ct. App. 1992)). | 6 | 7 |
State v. Medinagreen2 sentences2015State v. Medina, 128 Idaho 19, 29 , 909 P.2d 637, 647 (Ct. App. 1996). 2015State v. Medina, 128 Idaho 19, 29 , 909 P.2d 637, 647 (Ct. App. 1996). | 6 | 6 |
Dunlap v. Stategreen2 sentences2025“The cumulative error doctrine refers to an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, show the absence of a fair trial in contravention of the defendant’s constitutional right to due process.” Dunlap v. State, 141 Idaho 50, 65-66 , 106 P.3d 376, 391-92 (2004) (quoting State v. Sheahan, 139 Idaho 267, 286 , 77 P.3d 956, 975 (2003)). 2025“The cumulative error doctrine refers to an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, show the absence of a fair trial in contravention of the defendant’s constitutional right to due process.” Dunlap v. State, 141 Idaho 50, 65-66 , 106 P.3d 376, 391-92 (2004) (quoting State v. Sheahan, 139 Idaho 267, 286 , 77 P.3d 956, 975 (2003)). | 5 | 7 |
Reynolds v. Stategreen2 sentences2018State v. Blackstead, 126 Idaho 14, 23 , 878 P.2d 188, 197 (Ct. App. 1994); Reynolds v. State, 126 Idaho 24, 32 , 878 P.2d 198, 206 (Ct. App. 1994). 2018State v. Blackstead, 126 Idaho 14, 23 , 878 P.2d 188, 197 (Ct. App. 1994); Reynolds v. State, 126 Idaho 24, 32 , 878 P.2d 198, 206 (Ct. App. 1994). | 5 | 5 |
State v. Blacksteadgreen2 sentences2018State v. Blackstead, 126 Idaho 14, 23 , 878 P.2d 188, 197 (Ct. App. 1994); Reynolds v. State, 126 Idaho 24, 32 , 878 P.2d 198, 206 (Ct. App. 1994). 2018State v. Blackstead, 126 Idaho 14, 23 , 878 P.2d 188, 197 (Ct. App. 1994); Reynolds v. State, 126 Idaho 24, 32 , 878 P.2d 198, 206 (Ct. App. 1994). | 5 | 5 |
State v. Russell James Parkergreen2 sentences2016Silk Touch cites criminal cases where this Court has held that “[u]nder the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Parker, 157 Idaho 132, 149 , 334 P.3d 806, 823 (2014). 2016Silk Touch cites criminal cases where this Court has held that “[u]nder the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Parker, 157 Idaho 132, 149 , 334 P.3d 806, 823 (2014). | 4 | 4 |
State v. Lovelassgreen2 sentences2000CUMULATIVE ERROR As we recently explained in State v. Lovelass, 133 Idaho 160, 171 , 983 P.2d 233, 244 (Ct.App.1999): The doctrine of cumulative error is predicated on the finding of error in the first instance. 2000CUMULATIVE ERROR As we recently explained in State v. Lovelass, 133 Idaho 160, 171 , 983 P.2d 233, 244 (Ct.App.1999): The doctrine of cumulative error is predicated on the finding of error in the first instance. | 4 | 4 |
Bruton v. United Statesgreen2 sentences2014“The presence of errors, however, does not by itself require the reversal of a conviction, since under due process a defendant is entitled to a fair trial, not an error-free trial.” State v. Moore, 131 Idaho 814, 823 , 965 P.2d 174, 183 (1998) (citing Bruton v. United States, 391 U.S. 123, 135 , 88 S.Ct. 1620, 1627-28 , 20 L.Ed.2d 476, 484-85 (1968)). “[A] necessary predicate to the application of the doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . “[I]t is well-established that alleged errors at trial, that are not followed by a contemporaneous objec 2014“The presence of errors, however, does not by itself require the reversal of a conviction, since under due process a defendant is entitled to a fair trial, not an error-free trial.” State v. Moore, 131 Idaho 814, 823 , 965 P.2d 174, 183 (1998) (citing Bruton v. United States, 391 U.S. 123, 135 , 88 S.Ct. 1620, 1627-28 , 20 L.Ed.2d 476, 484-85 (1968)). “[A] necessary predicate to the application of the doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . “[I]t is well-established that alleged errors at trial, that are not followed by a contemporaneous objec | 3 | 5 |
State v. Sheahangreen2 sentences2025“The cumulative error doctrine refers to an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, show the absence of a fair trial in contravention of the defendant’s constitutional right to due process.” Dunlap v. State, 141 Idaho 50, 65-66 , 106 P.3d 376, 391-92 (2004) (quoting State v. Sheahan, 139 Idaho 267, 286 , 77 P.3d 956, 975 (2003)). 2025“The cumulative error doctrine refers to an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, show the absence of a fair trial in contravention of the defendant’s constitutional right to due process.” Dunlap v. State, 141 Idaho 50, 65-66 , 106 P.3d 376, 391-92 (2004) (quoting State v. Sheahan, 139 Idaho 267, 286 , 77 P.3d 956, 975 (2003)). | 3 | 4 |
State v. David Leon Johnsongreen2 sentences2021“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” Garcia, 166 Idaho at ___ , 462 P.3d at 1142–43 (quoting State v. Johnson, 163 Idaho 412 , 428, 414 P.3d 234, 250 (2018)). “[A] necessary predicate to the application of the [cumulative error] doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . 2021“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” Garcia, 166 Idaho at ___ , 462 P.3d at 1142–43 (quoting State v. Johnson, 163 Idaho 412 , 428, 414 P.3d 234, 250 (2018)). “[A] necessary predicate to the application of the [cumulative error] doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . | 3 | 3 |
State v. Paynegreen2 sentences2015“When there is an ‘accumulation of irregularities, each of which by itself might be harmless, but when aggregated, the errors show the absence of a fair trial,’ the cumulative error doctrine requires a reversal of the conviction as the trial has contravened the defendant’s right to due process.” State v. Payne, 146 Idaho 548, 568 , 199 P.3d 123, 143 (2008) (quoting State v. Field, 144 Idaho 559, 572-73 , 165 P.3d 273, 286-87 (2007)). “[A] necessary predicate to the application of the doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . 2015“When there is an ‘accumulation of irregularities, each of which by itself might be harmless, but when aggregated, the errors show the absence of a fair trial,’ the cumulative error doctrine requires a reversal of the conviction as the trial has contravened the defendant’s right to due process.” State v. Payne, 146 Idaho 548, 568 , 199 P.3d 123, 143 (2008) (quoting State v. Field, 144 Idaho 559, 572-73 , 165 P.3d 273, 286-87 (2007)). “[A] necessary predicate to the application of the doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . | 3 | 3 |
State v. Grossgreen2 sentences2015See State v. Gross, 146 Idaho 15, 21 , 189 P.3d 477, 483 (CLApp. 2008) (“The cumulative error doctrine refers to an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, show the absence of a fair trial in contravention of the defendant’s right to due process.”) (citing State v. Moore, 181 Idaho 814 , 823, 965 P.2d 174, 183 (1998)). 2015See State v. Gross, 146 Idaho 15, 21 , 189 P.3d 477, 483 (CLApp. 2008) (“The cumulative error doctrine refers to an accumulation of irregularities, each of which by itself might be harmless, but when aggregated, show the absence of a fair trial in contravention of the defendant’s right to due process.”) (citing State v. Moore, 181 Idaho 814 , 823, 965 P.2d 174, 183 (1998)). | 3 | 3 |
Boman v. Stategreen2 sentences2024Boman, 129 Idaho at 527 , 27 P.2d at 917. 2013Boman v. State, 129 Idaho 520 , 527, 927 P.2d 910 , 917 (Ct. App. 1996). | 1 | 2 |
State v. Samuelgreen2 sentences2022“Under the cumulative errors doctrine, an accumulation of irregularities, each of which might be harmless in itself, may in the aggregate reveal the absence of a fair trial in contravention of the defendant’s right to due process.” State v. Samuel, 165 Idaho 746, 778 , 452 P.3d 768, 800 (2019) (quoting State v. Martinez, 125 Idaho 445, 453 , 872 P.2d 708, 716 (1994)). 2022“Under the cumulative errors doctrine, an accumulation of irregularities, each of which might be harmless in itself, may in the aggregate reveal the absence of a fair trial in contravention of the defendant’s right to due process.” State v. Samuel, 165 Idaho 746, 778 , 452 P.3d 768, 800 (2019) (quoting State v. Martinez, 125 Idaho 445, 453 , 872 P.2d 708, 716 (1994)). | 1 | 2 |
State v. Higginsgreen2 sentences2010In State v. Higgins, 122 Idaho 590 , 836 P.2d 536 (1992), this Court considered whether alleged errors not objected to during trial, that were not deemed fundamental, could be reviewed under the cumulative error doctrine. 2010In State v. Higgins, 122 Idaho 590 , 836 P.2d 536 (1992), this Court considered whether alleged errors not objected to during trial, that were not deemed fundamental, could be reviewed under the cumulative error doctrine. | 1 | 2 |
Ross v. Justice Court of Brawley Tp.green1 sentence2024Boman, 129 Idaho at 527 , 27 P.2d at 917. | 1 | 1 |
Idaho Dep't of Health & Welfare v. Doe (In Re Interest of Doe)green1 sentence2022See Idaho Dep’t of Health & Welfare v. Jane Doe (2018-24), 164 Idaho 143 , 147, 426 P.3d 1243, 1247 (2018) (noting appellate court does not address issues not supported by cogent argument and citation to legal authority). | 1 | 1 |
State v. Harrisongreen2 sentences2021See State v. Field, 144 Idaho 559, 572-73 , 165 P.3d 273, 286-87 (2007) (holding that trial court correctly denied motion for mistrial based on prosecutorial misconduct but concluding that prosecutorial misconduct contributed to cumulative error, requiring reversal); State v. Harrison, 136 Idaho 504, 508 , 37 P.3d 1, 5 (Ct. App. 2001) (analyzing whether two errors that formed the basis for a motion for a mistrial required reversal under cumulative error doctrine). 9 instruction, in light of the other evidence discussed above, the aggregate effect of the errors did not deprive Gunter of a fair 2021See State v. Field, 144 Idaho 559, 572-73 , 165 P.3d 273, 286-87 (2007) (holding that trial court correctly denied motion for mistrial based on prosecutorial misconduct but concluding that prosecutorial misconduct contributed to cumulative error, requiring reversal); State v. Harrison, 136 Idaho 504, 508 , 37 P.3d 1, 5 (Ct. App. 2001) (analyzing whether two errors that formed the basis for a motion for a mistrial required reversal under cumulative error doctrine). 9 instruction, in light of the other evidence discussed above, the aggregate effect of the errors did not deprive Gunter of a fair | 1 | 1 |
| VFP VC v. Dakota Co.green | 1 | 1 |
Mitchell James Bias v. Stategreen2 sentences2020Bias v. State, 159 Idaho 696, 705 , 365 P.3d 1050, 1059 (Ct. App. 2015) (citing State v. Adamcik, 152 Idaho 445, 483 , 272 P.3d 417, 455 (2012)). 2020Bias v. State, 159 Idaho 696, 705 , 365 P.3d 1050, 1059 (Ct. App. 2015) (citing State v. Adamcik, 152 Idaho 445, 483 , 272 P.3d 417, 455 (2012)). | 1 | 1 |
| Powell v. Sellersgreen | 1 | 1 |
| Tyrell Ramsey v. Stategreen | 1 | 1 |
| State v. Zichkogreen | 1 | 1 |
| Edward Stevens v. Stategreen | 1 | 1 |
| State v. Shackelfordgreen | 1 | 1 |
| State v. Ellingtongreen | 1 | 1 |
| State v. Grovegreen | 1 | 1 |
| Benewah County Cattlemen's Ass'n v. Board of County Commissionersgreen | 1 | 1 |
| State v. Vance Everett Thummgreen | 1 | 1 |
| State v. Paciorekgreen | 1 | 1 |
| State v. Graygreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Reyes
green
2 sentences2025“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Reyes, 169 Idaho 781 , 791, 503 P.3d 997 , 1007 (2022) (quotation marks omitted). 2025“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” State v. Reyes, 169 Idaho 781 , 791, 503 P.3d 997 , 1007 (2022) (quotation marks omitted). | 1 | 2025–2025 |
State v. Garcia
green
2 sentences2021“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” Garcia, 166 Idaho at ___ , 462 P.3d at 1142–43 (quoting State v. Johnson, 163 Idaho 412 , 428, 414 P.3d 234, 250 (2018)). “[A] necessary predicate to the application of the [cumulative error] doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . 2021“Under the doctrine of cumulative error, a series of errors, harmless in and of themselves, may in the aggregate show the absence of a fair trial.” Garcia, 166 Idaho at ___ , 462 P.3d at 1142–43 (quoting State v. Johnson, 163 Idaho 412 , 428, 414 P.3d 234, 250 (2018)). “[A] necessary predicate to the application of the [cumulative error] doctrine is a finding of more than one error.” Perry, 150 Idaho at 230 , 245 P.3d at 982 . | 1 | 2021–2021 |
| State v. Cobell green | 1 | 2013–2013 |
| North Carolina v. Alford green | 1 | 2013–2013 |
| Virginia v. Moore green | 1 | 2010–2010 |
| State v. Lusby green | 1 | 2010–2010 |
| State v. Raudebaugh green | 1 | 2010–2010 |
| State v. Hayes green | 1 | 2008–2008 |
| State v. McKenzie green | 1 | 1990–1990 |
| McKenzie v. Montana green | 1 | 1990–1990 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.