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

19 Pennsylvania opinions name it 2 courts 2008–2026 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 (7)

CaseFollowedCited
Commonwealth v. Wrightgreen
pa · 2008 · cited in 10 Pennsylvania opinions naming this issue, 2011–2024
2 sentences

2024Finally, Appellant summarily concludes that the two evidentiary rulings “combined prejudiced the jury as to prevent him from receiving a fair trial.” Appellant’s Br. at 22. “[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, 961 A.2d 119, 158 (Pa. 2008); see also Commonwealth v. Small, 980 A.2d 549, 579 (Pa. 2009) (concluding that a broad and vague claim of the prejudicial effect of cumulative errors di

2022In reaching this conclusion we note that our Supreme Court has long recognized that “no number of failed [ineffectiveness] claims may collectively warrant relief if they fail to do so individually.” Commonwealth v. Johnson, 966 A.2d 523, 532 (Pa. 2009) (citations omitted). “[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, 961 A.2d 119, 158 (Pa. 2008) (emphasis added).

910
Commonwealth v. Hutchinsongreen
pa · 2011 · cited in 11 Pennsylvania opinions naming this issue, 2017–2026
2 sentences

2026Our Supreme Court has stated that “[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. Hutchinson, 25 A.3d 277, 318-19 (Pa. 2011) (citation omitted).

2026Our Supreme Court has held that “[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. Hutchinson, 25 A.3d 277 , 318–19 (Pa. 2011) (citations omitted).

711
Commonwealth v. Smallgreen
pa · 2009 · cited in 4 Pennsylvania opinions naming this issue, 2011–2026
2 sentences

2024Finally, Appellant summarily concludes that the two evidentiary rulings “combined prejudiced the jury as to prevent him from receiving a fair trial.” Appellant’s Br. at 22. “[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, 961 A.2d 119, 158 (Pa. 2008); see also Commonwealth v. Small, 980 A.2d 549, 579 (Pa. 2009) (concluding that a broad and vague claim of the prejudicial effect of cumulative errors di

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

44
Commonwealth v. Sepulvedagreen
pa · 2012 · cited in 2 Pennsylvania opinions naming this issue, 2025–2026
2 sentences

2026Additionally, “no number of failed - 35 - J-S02024-26 claims may collectively warrant relief if they fail to do so individually.” Commonwealth v. Sepulveda, 55 A.3d 1108, 1150 (Pa. 2012) (citation and brackets omitted).

2025Additionally, “no number of failed claims may collectively warrant - 13 - J-S17028-25 relief i[f] they fail to do so individually.” Commonwealth v. Sepulveda, 55 A.3d 1108, 1150 (Pa. 2012) (citation omitted).

22
Commonwealth v. Johnsongreen
pa · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022In reaching this conclusion we note that our Supreme Court has long recognized that “no number of failed [ineffectiveness] claims may collectively warrant relief if they fail to do so individually.” Commonwealth v. Johnson, 966 A.2d 523, 532 (Pa. 2009) (citations omitted). “[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, 961 A.2d 119, 158 (Pa. 2008) (emphasis added).

11
Commonwealth v. Michaelgreen
pa · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008See Commonwealth v. Michael, 562 Pa. 356 , 755 A.2d 1274, 1281 (2000) (citing Commonwealth v. McGill, 545 Pa. 180 , 680 A.2d 1131, 1136 (1996) (there can be no cumulative effect of prejudice when there was no harm in first instance)).

2008See Commonwealth v. Michael, 562 Pa. 356 , 755 A.2d 1274, 1281 (2000) (citing Commonwealth v. McGill, 545 Pa. 180 , 680 A.2d 1131, 1136 (1996) (there can be no cumulative effect of prejudice when there was no harm in first instance)).

11
Commonwealth v. McGillgreen
pa · 1996 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
2 sentences

2008See Commonwealth v. Michael, 562 Pa. 356 , 755 A.2d 1274, 1281 (2000) (citing Commonwealth v. McGill, 545 Pa. 180 , 680 A.2d 1131, 1136 (1996) (there can be no cumulative effect of prejudice when there was no harm in first instance)).

2008See Commonwealth v. Michael, 562 Pa. 356 , 755 A.2d 1274, 1281 (2000) (citing Commonwealth v. McGill, 545 Pa. 180 , 680 A.2d 1131, 1136 (1996) (there can be no cumulative effect of prejudice when there was no harm in first instance)).

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 (1)

CaseCitedYears
Commonwealth v. Koehler green
pa · 2012
1 sentence

2025However, “[w]hen the failure of individual [PCRA] claims is grounded in lack of prejudice, ... then the cumulative prejudice from those individual claims may properly be assessed.” Koehler, 36 A.3d at 161 - 14 - J-S28030-25 “[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. Hutchinson, 25 A.3d 277, 351-52 (Pa. 2011) (citation omitted).

12025–2025

Statutes the citing opinions construe

PA § 42 Pa. Cons. Stat. § 9543 (6) PA § 18 Pa. Cons. Stat. § 2702 (3) PA § 18 Pa. Cons. Stat. § 3502 (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

KS 124 (1992–2024) AL 40 (1999–2026) PA 19 (2008–2026) NY 17 (1998–2025) TX 17 (1974–2024) OH 16 (1991–2025) IL 15 (1974–2022) CA 13 (1978–2023) MI 5 (2015–2025) WI 5 (1954–2024) IA 5 (1996–2024) TN 5 (1988–2024) FL 5 (1989–2013) IN 4 (2012–2018) MS 4 (2000–2005) WV 4 (1980–2023) AZ 4 (1992–2026) NJ 3 (1975–1996) KY 3 (1958–2026) MN 3 (1984–2006) ND 2 (2011–2011) MA 2 (1999–2024) MD 2 (2020–2021) GA 2 (2016–2021) WA 2 (2016–2024) MO 2 (1973–1983) SD 2 (1990–1995)

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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