cumulative claim (Pennsylvania) · Go Syfert
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cumulative claim in Pennsylvania

22 Pennsylvania opinions name it 4 courts 1979–2026 9 in the last five years

The cases below were cited by Pennsylvania 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.

Followed or applied (17)

CaseFollowedCited
Commonwealth v. Rolangreen
pasuperct · 2008 · cited in 5 Pennsylvania opinions naming this issue, 2014–2022
2 sentences

2022We have repeatedly held that “an appellant cannot bootstrap a series of meritless claims into a cumulative claim of error.” See Commonwealth v. Rolan, 964 A.2d 398, 411 (Pa. Super. 2008) (“No number of failed claims may collectively attain merit if they could not do so individually.”).

2019See Commonwealth v. Rolan, 2008 PA Super 291 , 964 A.2d 398, 411 (Pa.Super. 2008) (“No number of failed claims may collectively attain merit if they could not do so individually.”) (quoting Commonwealth v. Williams, 532 Pa. 265 , 615 A.2d 716, 722 (Pa. 1992)) (emphasis in original).

55
Commonwealth v. Williamsgreen
pa · 1992 · cited in 4 Pennsylvania opinions naming this issue, 2014–2019
2 sentences

2019See Commonwealth v. Rolan, 2008 PA Super 291 , 964 A.2d 398, 411 (Pa.Super. 2008) (“No number of failed claims may collectively attain merit if they could not do so individually.”) (quoting Commonwealth v. Williams, 532 Pa. 265 , 615 A.2d 716, 722 (Pa. 1992)) (emphasis in original).

2019See Commonwealth v. Rolan, 2008 PA Super 291 , 964 A.2d 398, 411 (Pa.Super. 2008) (“No number of failed claims may collectively attain merit if they could not do so individually.”) (quoting Commonwealth v. Williams, 532 Pa. 265 , 615 A.2d 716, 722 (Pa. 1992)) (emphasis in original).

44
Commonwealth v. Spotzgreen
pa · 2011 · cited in 2 Pennsylvania opinions naming this issue, 2020–2021
2 sentences

2021See Commonwealth v. Spotz, 18 A.3d 244, 321 (Pa. 2011) (establishing that, while “lack of merit” claims can never result in a cumulative error claim cognizable under the PCRA, a cumulative prejudice claim may have validity if there are multiple instances of trial counsel’s ineffective representation).

2020Commonwealth v. Spotz, 18 A.3d 244, 321 (Pa. 2011) (“no number of failed claims may collectively warrant relief if they fail to do so individually”).

22
Commonwealth v. Kearneygreen
pasuperct · 2014 · cited in 2 Pennsylvania opinions naming this issue, 2015–2021
2 sentences

2021Furthermore, “it is well-settled that an appellant cannot bootstrap a series of meritless claims into a cumulative claim of error.” Commonwealth v. Kearney, 92 A.3d 51, 62 (Pa. Super. 2014) (citations omitted).

2015As Hairston concedes, it is well-established that “an appellant cannot bootstrap a series of meritless claims into a cumulative claim of error.” Commonwealth v. Kearney, 92 A.3d 51, 62 (Pa. Super. 2014), appeal denied, 101 A.3d 102 (Pa. 2014).

22
Commonwealth v. Johnsongreen
pa · 2009 · cited in 2 Pennsylvania opinions naming this issue, 2018–2023
2 sentences

2023"When the failure of individual claims is grounded in lack of prejudice, then the cumulative prejudice from those individual claims may properly be assessed." Id. (quoting Johnson, 966 A.2d at 532 ). 30 Here, Defendant's claims I- IV(b) failed due to lack of merit, thus there is no basis for a cumulative error claim on those claims.

2023"When the failure of individual claims is grounded in lack of prejudice, then the cumulative prejudice from those individual claims may properly be assessed." Id. (quoting Johnson, 966 A.2d at 532 ). 30 Here, Defendant's claims I- IV(b) failed due to lack of merit, thus there is no basis for a cumulative error claim on those claims.

12
Commonwealth v. Williamsgreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026However, Brady does not create a general constitutional right to discovery, or “grant a criminal defendant unfettered access to the Commonwealth’s files.” Commonwealth v. Lambert, 884 A.2d 848, 854 (Pa. 2005); see also Williams, 732 A.2d at 1175–76.

11
Commonwealth v. Abdul-Salaamgreen
pa · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026In effect, 104 See Commonwealth v. Abdul-Salaam, 42 A.3d 983, 987 (Pa. 2012) (even assuming a cumulative analysis of multiple items of Brady non-disclosure, concluding that materiality was not established due to a failure to show a reasonable probability of a different outcome with the benefit of the Brady evidence in question). 105 145 S. Ct. 612 (U.S. 2025).

11
Commonwealth v. Lambertgreen
pa · 2005 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026However, Brady does not create a general constitutional right to discovery, or “grant a criminal defendant unfettered access to the Commonwealth’s files.” Commonwealth v. Lambert, 884 A.2d 848, 854 (Pa. 2005); see also Williams, 732 A.2d at 1175–76.

11
Commonwealth v. Fordgreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022See Ford, supra. In his final claim, Ivy contends that even if none of his prior claims warrants relief, he is entitled to relief under the cumulative error doctrine.

11
Commonwealth v. Harrisgreen
pasuperct · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See Harris, 979 A.2d at 391 - 92. - 23 - J-S20013-21 Appellant “cannot bootstrap a series of meritless claims into a cumulative claim of error.” See Kearney, 92 A.3d at 62 .

11
Commonwealth v. Bennergreen
pasuperct · 2016 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See Benner, supra; see also PCRA Court Opinion, 5/12/21, at 24-25.

11
Commonwealth v. Simpson, R., Apltgreen
pa · 2015 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021See Commonwealth v. Simpson, 112 A.3d 1194, 1205-06 (Pa. 2015).

11
Commonwealth v. Hutchinsongreen
pa · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
1 sentence

2017“Where a claimant has failed to prove prejudice as the result of any individual errors, he cannot prevail on a cumulative effect claim unless he demonstrates how the particular cumulation requires a different analysis.” Commonwealth v. Hutchinson, 25 A.3d 277, 319 (Pa. 2011) (citations and brackets omitted).

11
Commonwealth v. Wrightgreen
pa · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016Moreover, when such a cumulative claim was further reviewed in Commonwealth v. Hutchinson, the Pennsylvania Supreme Court found: '[W]here a claimant has failed to prove prejudice as the result of any individual errors, he cannot prevail on a cumulative effect claim unless he demonstrates how the particular cumulation requires a different analysis.' Commonwealth v. Wright, 599 Pa. 270 , 961 A.2d 119, 158 (2008); see also Commonwealth v. Small, 602 Pa. 425 , [475-76] 980 A.2d 549, 579 (2009) (concluding that a 88 See Sections I and II. 79 broad and vague claim of the prejudicial effect of cumula

2016Moreover, when such a cumulative claim was further reviewed in Commonwealth v. Hutchinson, the Pennsylvania Supreme Court found: '[W]here a claimant has failed to prove prejudice as the result of any individual errors, he cannot prevail on a cumulative effect claim unless he demonstrates how the particular cumulation requires a different analysis.' Commonwealth v. Wright, 599 Pa. 270 , 961 A.2d 119, 158 (2008); see also Commonwealth v. Small, 602 Pa. 425 , [475-76] 980 A.2d 549, 579 (2009) (concluding that a 88 See Sections I and II. 79 broad and vague claim of the prejudicial effect of cumula

11
Commonwealth v. Smallgreen
pa · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016Moreover, when such a cumulative claim was further reviewed in Commonwealth v. Hutchinson, the Pennsylvania Supreme Court found: '[W]here a claimant has failed to prove prejudice as the result of any individual errors, he cannot prevail on a cumulative effect claim unless he demonstrates how the particular cumulation requires a different analysis.' Commonwealth v. Wright, 599 Pa. 270 , 961 A.2d 119, 158 (2008); see also Commonwealth v. Small, 602 Pa. 425 , [475-76] 980 A.2d 549, 579 (2009) (concluding that a 88 See Sections I and II. 79 broad and vague claim of the prejudicial effect of cumula

2016Moreover, when such a cumulative claim was further reviewed in Commonwealth v. Hutchinson, the Pennsylvania Supreme Court found: '[W]here a claimant has failed to prove prejudice as the result of any individual errors, he cannot prevail on a cumulative effect claim unless he demonstrates how the particular cumulation requires a different analysis.' Commonwealth v. Wright, 599 Pa. 270 , 961 A.2d 119, 158 (2008); see also Commonwealth v. Small, 602 Pa. 425 , [475-76] 980 A.2d 549, 579 (2009) (concluding that a 88 See Sections I and II. 79 broad and vague claim of the prejudicial effect of cumula

11
Commonwealth v. Braceygreen
pa · 2001 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See also Commonwealth v. Bracey supra 568 Pa. at 273 , Fn. 4, 795 A.2d at 940 , Fn. 4 (" ... [ A]n undeveloped argument, which fails to meaningfully discuss and apply the standard governing review of ineffectiveness claims, simply does not satisfy Appellant's burden of establishing that he is entitled to any relief.") 80 Although the shared failure of individual ineffectiveness challenges based on a lack of prejudice can warrant a cumulative error review, Commonwealth v. Elliot supra 622 Pa. at 294 , 80 A.3d at 450 , Defendant Mann's numerous attacks on his trial, direct appeal, and collateral

2016See also Commonwealth v. Bracey supra 568 Pa. at 273 , Fn. 4, 795 A.2d at 940 , Fn. 4 (" ... [ A]n undeveloped argument, which fails to meaningfully discuss and apply the standard governing review of ineffectiveness claims, simply does not satisfy Appellant's burden of establishing that he is entitled to any relief.") 80 Although the shared failure of individual ineffectiveness challenges based on a lack of prejudice can warrant a cumulative error review, Commonwealth v. Elliot supra 622 Pa. at 294 , 80 A.3d at 450 , Defendant Mann's numerous attacks on his trial, direct appeal, and collateral

11
Commonwealth v. Elliottgreen
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
2 sentences

2016See also Commonwealth v. Bracey supra 568 Pa. at 273 , Fn. 4, 795 A.2d at 940 , Fn. 4 (" ... [ A]n undeveloped argument, which fails to meaningfully discuss and apply the standard governing review of ineffectiveness claims, simply does not satisfy Appellant's burden of establishing that he is entitled to any relief.") 80 Although the shared failure of individual ineffectiveness challenges based on a lack of prejudice can warrant a cumulative error review, Commonwealth v. Elliot supra 622 Pa. at 294 , 80 A.3d at 450 , Defendant Mann's numerous attacks on his trial, direct appeal, and collateral

2016See also Commonwealth v. Bracey supra 568 Pa. at 273 , Fn. 4, 795 A.2d at 940 , Fn. 4 (" ... [ A]n undeveloped argument, which fails to meaningfully discuss and apply the standard governing review of ineffectiveness claims, simply does not satisfy Appellant's burden of establishing that he is entitled to any relief.") 80 Although the shared failure of individual ineffectiveness challenges based on a lack of prejudice can warrant a cumulative error review, Commonwealth v. Elliot supra 622 Pa. at 294 , 80 A.3d at 450 , Defendant Mann's numerous attacks on his trial, direct appeal, and collateral

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Commonwealth v. Koehler green
pa · 2012
2 sentences

2021Commonwealth v. Koehler, 614 Pa. 159 (Pa. 2012).

2021Commonwealth v. Koehler, 614 Pa. 159 (Pa. 2012).

12021–2021
Berwick Industries v. Workmen's Compensation Appeal Board green
pa · 1994
2 sentences

2011Cerro also argues that we should rely on Berwick Industries v. Workers’ Compensation Appeal Board (Spaid), 537 Pa. 326 , 643 A.2d 1066 (1994), for the proposition that it does not have to pay any medical benefits because Claimant failed to timely file his claim against Accurate which the WCJ found was time barred.

2011Cerro also argues that we should rely on Berwick Industries v. Workers’ Compensation Appeal Board (Spaid), 537 Pa. 326 , 643 A.2d 1066 (1994), for the proposition that it does not have to pay any medical benefits because Claimant failed to timely file his claim against Accurate which the WCJ found was time barred.

12011–2011
Village at Camelback Property Owners Assn. Inc. v. Carr green
pa · 1988
2 sentences

1995In the case of Village at Camelback v. Carr, 371 Pa. Super. 452 , 538 A.2d 528 (1988), the Pennsylvania Superior Court in setting out a general standard for piercing the corporate veil stated: “The legal fiction that a corporation is a legal entity separate and distinct from its shareholders was designed to serve convenience and justice, . . . and will be disregarded whenever justice or public policy require and where rights of innocent parties are not prejudiced nor the theory of the corporate entity rendered useless. . . .

1995In the case of Village at Camelback v. Carr, 371 Pa. Super. 452 , 538 A.2d 528 (1988), the Pennsylvania Superior Court in setting out a general standard for piercing the corporate veil stated: “The legal fiction that a corporation is a legal entity separate and distinct from its shareholders was designed to serve convenience and justice, . . . and will be disregarded whenever justice or public policy require and where rights of innocent parties are not prejudiced nor the theory of the corporate entity rendered useless. . . .

11995–1995
New Castle Orthopedic Associates v. Burns green
pa · 1978
2 sentences

1984Belief pursuant to the cumulative test for the issuance of preliminary relief enumerated by our Supreme Court in New Castle Orthopedic Associates v. Burns, 481 Pa. 460 , 392 A.2d 1383 (1978), was rejected because it was the Chancellor’s perception, after argument, that the abrupt emasculation of the City’s taxing scheme would have had a disastrous impact upon the City’s finances.

1984Belief pursuant to the cumulative test for the issuance of preliminary relief enumerated by our Supreme Court in New Castle Orthopedic Associates v. Burns, 481 Pa. 460 , 392 A.2d 1383 (1978), was rejected because it was the Chancellor’s perception, after argument, that the abrupt emasculation of the City’s taxing scheme would have had a disastrous impact upon the City’s finances.

11984–1984
DuBree v. Commonwealth green
pa · 1978
1 sentence

1979DuBree, supra at 546 , 393 A.2d at 296 , stands for the proposition that “[wjhere, but for the defendant’s status, a right of action would lie under analogous rules of law, and no public policy would be promoted in shielding a defendant from liability, and the plaintiff has not failed to pursue existing remedies, denial of the possibility of recovery is unjustified.” This is a cumulative test; all three elements must be present.

11979–1979

Statutes the citing opinions construe

PA § 18 Pa. Cons. Stat. § 2502 (5) PA § 18 Pa. Cons. Stat. § 6106 (3) PA § 18 Pa. Cons. Stat. § 903 (3) PA § 18 Pa. Cons. Stat. § 907 (3) PA § 42 Pa. Cons. Stat. § 9543 (3)

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.

Where else courts name it

OH 763 (1984–2026) WA 493 (1981–2026) CA 282 (1961–2026) TN 276 (2001–2026) KS 247 (1994–2026) NM 222 (1967–2026) UT 194 (1986–2026) ID 183 (1987–2026) CO 143 (1983–2026) MS 136 (1991–2026) TX 132 (1948–2026) GA 106 (1984–2026) NV 99 (1994–2026) FL 98 (1985–2025) KY 89 (2012–2026) OK 76 (1988–2026) NJ 75 (1989–2026) WV 66 (1976–2025) MT 55 (1976–2026) AL 43 (1980–2022) IL 42 (1982–2026) MI 35 (1995–2026) AZ 35 (1966–2026) WY 29 (1991–2025) AR 29 (1994–2025) MN 23 (1989–2026) PA 22 (1979–2026) SC 22 (2005–2026) OR 17 (2000–2026) MA 12 (1996–2025) CT 12 (1980–2021) NE 12 (2002–2026) DE 11 (2014–2025) NC 10 (2014–2026) IA 10 (2017–2025) LA 8 (2009–2024) VI 6 (2012–2013) MD 5 (1999–2022) WI 4 (2003–2022) SD 3 (2019–2026) ME 3 (2013–2024) ND 2 (2013–2013) IN 2 (2009–2018) VT 2 (2017–2018)

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.

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