instances of trial-court error (Ohio) · Go Syfert
← Ohio issues

instances of trial-court error in Ohio

120 Ohio opinions name it 3 courts 2001–2026 71 in the last five years

The cases below were cited by Ohio 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 (20)

CaseFollowedCited
State v. Beemangreen
ohio · 1995 · cited in 17 Ohio opinions naming this issue, 2001–2026
2 sentences

2016Cumulative Error {¶ 151} In proposition of law No. 20, Belton urges the court to reverse his conviction or, alternatively, his sentence, on grounds of cumulative error. {¶ 152} The cumulative-error doctrine provides that “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , at ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191 , 509 N.E.2d 1256 (1987), par

2015Cumulative Error {¶ 95} In proposition of law No. 7, Johnson urges the court to reverse his sentence on grounds of cumulative error and order a new trial. {¶ 96} The cumulative-error doctrine provides that “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191 , 509 N.E.2d 1256 (1987), paragraph tw

417
State v. Durantgreen
ohioctapp · 2004 · cited in 3 Ohio opinions naming this issue, 2022–2023
2 sentences

2023We disagree. {¶ 110} Pursuant to the cumulative error doctrine “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even -49- though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191, 196-197 , 509 N.E.2d 1256 (1987). “[I]n order * * * to consider whether ‘cumulative’ error is present, we would first have to find that multiple errors were committed in this

2023We disagree. {¶ 110} Pursuant to the cumulative error doctrine “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even -49- though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191, 196-197 , 509 N.E.2d 1256 (1987). “[I]n order * * * to consider whether ‘cumulative’ error is present, we would first have to find that multiple errors were committed in this

33
State v. DeMarcogreen
ohio · 1987 · cited in 46 Ohio opinions naming this issue, 2012–2026
2 sentences

2026“A conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 2012- Ohio-2577, ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191 (1987), paragraph two of the syllabus. {¶ 26} Here, assuming the cumulative error doctrine is applicable to a non-trial situation, we have found no error, let alone cumulative error, that would have acted to deprive Smith of his constitutional rights.

2026Under the cumulative error doctrine, “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 2012-Ohio-2577, ¶ 223 , citing State v. DeMarco, 31 Ohio St.3d 191, 196-197 (1987).

246
State v. Hillgreen
ohio · 1996 · cited in 5 Ohio opinions naming this issue, 2016–2026
2 sentences

2026But even if there are some errors, they do not “become prejudicial by sheer weight of numbers.” State v. Hill, 75 Ohio St.3d 195, 212 (1996), citing State v. Davis, 62 Ohio St.3d 326, 348 (1991). 33 {¶ 98} In support of his cumulative error argument, Petaway relies on the arguments made in his prior assignments of error regarding the purported improper admission of evidence.

2024But “errors ‘cannot become prejudicial by sheer weight of numbers.’ ” State v. McKelton, 148 Ohio St.3d 261, 2016-Ohio-5735, 70 N.E.2d 508, ¶ 322, quoting State v. Hill, 75 Ohio St.3d 195, 212, 661 N.E.2d 1068 (1996). {¶ 290} The ambiguous reference to a polygraph examination (see proposition of law No. III) did not deny Knuff a fair trial.

25
City of Norwood v. Burtongreen
ohio · 2006 · cited in 3 Ohio opinions naming this issue, 2013–2020
2 sentences

2020However, because Madison “offers no further analysis, this proposition lacks substance.” State v. Sapp, 105 Ohio St.3d 104 , 2004-Ohio-7008 , 822 N.E.2d 1239, ¶ 103 ; see also Bethel, 110 Ohio St.3d 416 , 2006-Ohio-4853 , 854 N.E.2d 150, at ¶ 197 .

2018However, because Myers "offers no further analysis, this proposition lacks substance." State v. Sapp , 105 Ohio St.3d 104 , 2004-Ohio-7008 , 822 N.E.2d 1239 , ¶ 103 ; see also State v. Bethel , 110 Ohio St.3d 416 , 2006-Ohio-4853 , 854 N.E.2d 150 , ¶ 197.

23
State v. Bethelgreen
ohio · 2006 · cited in 3 Ohio opinions naming this issue, 2013–2020
2 sentences

2020However, because Madison “offers no further analysis, this proposition lacks substance.” State v. Sapp, 105 Ohio St.3d 104 , 2004-Ohio-7008 , 822 N.E.2d 1239, ¶ 103 ; see also Bethel, 110 Ohio St.3d 416 , 2006-Ohio-4853 , 854 N.E.2d 150, at ¶ 197 .

2018However, because Myers "offers no further analysis, this proposition lacks substance." State v. Sapp , 105 Ohio St.3d 104 , 2004-Ohio-7008 , 822 N.E.2d 1239 , ¶ 103 ; see also State v. Bethel , 110 Ohio St.3d 416 , 2006-Ohio-4853 , 854 N.E.2d 150 , ¶ 197.

23
State v. Allengreen
ohioctapp · 2016 · cited in 2 Ohio opinions naming this issue, 2026–2026
2 sentences

2026“However, the doctrine of cumulative error is inapplicable when the alleged errors are found to be harmless or nonexistent.” State v. Allen, 2016-Ohio-102, ¶ 53 (8th Dist.), citing State v. Brown, 2003-Ohio-5059 , ¶ 48.

2026“However, the doctrine of cumulative error is inapplicable when the alleged errors are found to be harmless or nonexistent.” State v. Allen, 2016-Ohio-102, ¶ 53 (8th Dist.), citing State v. Brown, 2003-Ohio-5059 , ¶ 48.

22
State v. Akladyousgreen
ohioctapp · 2023 · cited in 2 Ohio opinions naming this issue, 2024–2025
2 sentences

2025"Under the doctrine of cumulative error[ ], a reviewing court 'will reverse a conviction when the cumulative effect of errors deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal.'" State v. Akladyous, 2023-Ohio-3105, ¶ 60 (12th Dist.), quoting State v. Kirkland, 2014- Ohio-1966, ¶ 140.

2024Cumulative Error {¶ 86} Creech argues the purported errors discussed within his third and fourth assignments of error amount to cumulative error. {¶ 87} "Under the doctrine of cumulative error[], a reviewing court 'will reverse a - 26 - Preble CA2023-05-005 conviction when the cumulative effect of errors deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal.'" State v. Akladyous, 2023-Ohio-3105, ¶ 60 (12th Dist.), quoting State v. Kirkland, 2014-Ohio-1966, ¶ 140 .

22
State v. Fromangreen
ohioctapp · 2022 · cited in 2 Ohio opinions naming this issue, 2024–2025
2 sentences

2025"The cumulative error doctrine is inapplicable when there are not multiple instances presented of harmless error." State v. Froman, 2022-Ohio-2726, ¶ 200 (12th Dist.), citing State v. Garner, 74 Ohio St.3d 49, 64 , 1995-Ohio-168 . {¶ 81} Here, we have found no prejudicial errors and only one harmless error— admission of Elliot's report into evidence.

2024"The cumulative error doctrine is inapplicable when there are not multiple instances presented of harmless error." State v. Froman, 2022-Ohio-2726, ¶ 200 (12th Dist.), citing State v. Garner, 74 Ohio St.3d 49, 64 , 1995-Ohio-168 (1995). {¶ 88} Here, we found, with respect to Creech's third assignment of error, that the trial court did not err when it denied Creech's request for a mistrial and that it properly instructed the jury regarding Chief Spurlock's statements about Creech's silence and request for counsel and regarding Creech's right not to testify.

22
State v. Mizegreen
ohioctapp · 2022 · cited in 2 Ohio opinions naming this issue, 2023–2023
2 sentences

2023We disagree. {¶ 110} Pursuant to the cumulative error doctrine “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even -49- though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191, 196-197 , 509 N.E.2d 1256 (1987). “[I]n order * * * to consider whether ‘cumulative’ error is present, we would first have to find that multiple errors were committed in this

2023We disagree. {¶ 110} Pursuant to the cumulative error doctrine “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even -49- though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191, 196-197 , 509 N.E.2d 1256 (1987). “[I]n order * * * to consider whether ‘cumulative’ error is present, we would first have to find that multiple errors were committed in this

22
State v. Powellgreen
ohio · 2012 · cited in 86 Ohio opinions naming this issue, 2013–2026
2 sentences

2026He contends that “if the errors complained of in the first three assignments of error, standing alone, do not call for reversal of his conviction, cumulatively, they deprived him of a fair trial.” (Appellant’s brief p. 14.) Under the cumulative-error doctrine, a conviction may be reversed when the cumulative effect of nonprejudicial errors “deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal.” State v. Garrett, 2022-Ohio-4218, ¶ 270 , citing State v. Powell, 2012-Ohio-2577, ¶ 223 .

2026Under the cumulative-error doctrine, a conviction may be reversed when the cumulative effect of nonprejudicial errors “deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal.” State v. Garrett, 2022-Ohio-4218, ¶ 270 , citing State v. Powell, 2012-Ohio-2577, ¶ 223 .

186
State v. Madrigalgreen
ohio · 2000 · cited in 5 Ohio opinions naming this issue, 2022–2023
2 sentences

2023We disagree. {¶ 110} Pursuant to the cumulative error doctrine “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even -49- though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191, 196-197 , 509 N.E.2d 1256 (1987). “[I]n order * * * to consider whether ‘cumulative’ error is present, we would first have to find that multiple errors were committed in this

2023We disagree. {¶ 110} Pursuant to the cumulative error doctrine “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even -49- though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191, 196-197 , 509 N.E.2d 1256 (1987). “[I]n order * * * to consider whether ‘cumulative’ error is present, we would first have to find that multiple errors were committed in this

15
Daniels v. Northcoast Anesthesia Providers, Inc.green
ohioctapp · 2018 · cited in 3 Ohio opinions naming this issue, 2020–2024
2 sentences

2024Cuyahoga No. 105125, 2018-Ohio-3562, ¶ 66 , quoting State v. McKelton, 148 Ohio St.3d 261 , 2016-Ohio-5735 , 70 N.E.3d 508, ¶ 321 .

2024Cuyahoga No. 105125, 2018-Ohio-3562, ¶ 66 , quoting State v. McKelton, 148 Ohio St.3d 261 , 2016-Ohio-5735 , 70 N.E.3d 508, ¶ 321 .

13
State v. Davisgreen
ohio · 1991 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026But even if there are some errors, they do not “become prejudicial by sheer weight of numbers.” State v. Hill, 75 Ohio St.3d 195, 212 (1996), citing State v. Davis, 62 Ohio St.3d 326, 348 (1991). 33 {¶ 98} In support of his cumulative error argument, Petaway relies on the arguments made in his prior assignments of error regarding the purported improper admission of evidence.

11
State v. Ward, 05ca13 (5-21-2007)green
ohioctapp · 2007 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025Before a reviewing court can find cumulative error, “it must find a reasonable probability that the outcome of the trial would have been different but for the combination of the separately Ross App. No. 24CA16 27 harmless errors.” State v. Ward, 2007-Ohio-2531, ¶ 49 (4th Dist.), citing State v. Thomas, 2001 WL 1103328 (2d Dist.

11
In re J.M.green
ohioctapp · 2012 · cited in 1 Ohio opinions naming this issue, 2025–2025
1 sentence

2025“To find cumulative error, a court must first find multiple errors committed at trial and determine that there is a reasonable probability that the outcome below would have been different but for the combination of the harmless errors.” In re J.M., 2012-Ohio-1467, ¶ 36 (3d Dist.).

11
State v. Craftgreen
ohioctapp · 2025 · cited in 1 Ohio opinions naming this issue, 2025–2025
11
State v. Huntergreen
ohio · 2011 · cited in 1 Ohio opinions naming this issue, 2022–2022
11
State v. Fraziergreen
ohio · 2007 · cited in 1 Ohio opinions naming this issue, 2016–2016
11
State v. Matthewsgreen
ohioctapp · 2010 · cited in 1 Ohio opinions naming this issue, 2013–2013
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (26)

CaseCitedYears
State v. Garner green
ohio · 1995
2 sentences

2016Cumulative Error {¶ 151} In proposition of law No. 20, Belton urges the court to reverse his conviction or, alternatively, his sentence, on grounds of cumulative error. {¶ 152} The cumulative-error doctrine provides that “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , at ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191 , 509 N.E.2d 1256 (1987), par

2015Cumulative Error {¶ 95} In proposition of law No. 7, Johnson urges the court to reverse his sentence on grounds of cumulative error and order a new trial. {¶ 96} The cumulative-error doctrine provides that “a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223, citing State v. DeMarco, 31 Ohio St.3d 191 , 509 N.E.2d 1256 (1987), paragraph tw

102001–2022
State v. McKelton (Slip Opinion) green
ohio · 2016
2 sentences

2023Under the cumulative error doctrine, “‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.’” State v. McKelton, 148 Ohio St.3d 261 , 2016-Ohio-5735 , 70 N.E.3d 508, ¶ 321 , quoting State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio2577, 971 N.E.2d 865 , ¶ 223.

2023Under the cumulative error doctrine, “‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.’” State v. McKelton, 148 Ohio St.3d 261 , 2016-Ohio-5735 , 70 N.E.3d 508, ¶ 321 , quoting State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio2577, 971 N.E.2d 865 , ¶ 223.

92017–2026
State v. Kirkland (Slip Opinion) green
ohio · 2014
2 sentences

2024Cumulative Error {¶ 86} Creech argues the purported errors discussed within his third and fourth assignments of error amount to cumulative error. {¶ 87} "Under the doctrine of cumulative error[], a reviewing court 'will reverse a - 26 - Preble CA2023-05-005 conviction when the cumulative effect of errors deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal.'" State v. Akladyous, 2023-Ohio-3105, ¶ 60 (12th Dist.), quoting State v. Kirkland, 2014-Ohio-1966, ¶ 140 .

2023Standards of Review {¶ 60} Under the doctrine of cumulative errors, a reviewing court "will reverse a conviction when the cumulative effect of errors deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal." State v. Kirkland, 140 Ohio St.3d 73 , 2014-Ohio-1966, ¶ 140 . {¶ 61} To prevail on an ineffective assistance of counsel claim, Akladyos must show his defense counsel's performance was deficient, and that he was prejudiced as a result.

72020–2026
State v. Froman (Slip Opinion) green
ohio · 2020
2 sentences

2025This Court disagrees. {¶58} “Under the doctrine of cumulative error, ‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.’” State v. Froman, 2020-Ohio-4523, ¶ 156 , quoting State v. Powell, 2012-Ohio-2577, ¶ 223 .

2024“Under the doctrine of cumulative error, ‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.’” State v. Froman, 162 Ohio St.3d 435 , 2020-Ohio-4523, ¶ 156 , quoting State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577, ¶ 223 .

72020–2025
State v. Garrett green
ohio · 2022
2 sentences

2026He contends that “if the errors complained of in the first three assignments of error, standing alone, do not call for reversal of his conviction, cumulatively, they deprived him of a fair trial.” (Appellant’s brief p. 14.) Under the cumulative-error doctrine, a conviction may be reversed when the cumulative effect of nonprejudicial errors “deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal.” State v. Garrett, 2022-Ohio-4218, ¶ 270 , citing State v. Powell, 2012-Ohio-2577, ¶ 223 .

2026Under the cumulative-error doctrine, a conviction may be reversed when the cumulative effect of nonprejudicial errors “deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal.” State v. Garrett, 2022-Ohio-4218, ¶ 270 , citing State v. Powell, 2012-Ohio-2577, ¶ 223 .

52023–2026
State v. Belton (Slip Opinion) green
ohio · 2016
2 sentences

2025Legal Standard {¶124} “The cumulative-error doctrine provides that ‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.’” State v. Belton, 2016-Ohio-1581, ¶ 169 , quoting State v. Powell, 2012-Ohio-2577, ¶ 223 .

2023The cumulative-error doctrine provides that ‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.’ State v. Belton, 149 Ohio St.3d 165 , 2016-Ohio-1581 , 74 N.E.3d 319, ¶ 169 , quoting State v. Powell, 132 Ohio St.3d 233 , 2012-Ohio-2577 , 971 N.E.2d 865 , ¶ 223.

52019–2025
State v. Sapp green
ohio · 2004
2 sentences

2022However, “[a]s [Drain] offers no further analysis, this proposition lacks substance.” State v. Sapp, 105 Ohio St.3d 104 , 2004-Ohio-7008 , 822 N.E.2d 1239, ¶ 103 .

2022However, “[a]s [Drain] offers no further analysis, this proposition lacks substance.” State v. Sapp, 105 Ohio St.3d 104 , 2004-Ohio-7008 , 822 N.E.2d 1239, ¶ 103 .

32018–2022
State v. Pickens (Slip Opinion) green
ohio · 2014
2 sentences

2021We disagree. {¶ 84} "Under the doctrine of accumulated error, a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal." State v. Pickens, 141 Ohio St.3d 462 , 2014-Ohio-5445, ¶ 230 , citation omitted, overruled in part on other grounds, State v. Bates, 159 Ohio St.3d 156 , 2020-Ohio-634 .

2021We disagree. {¶ 84} "Under the doctrine of accumulated error, a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal." State v. Pickens, 141 Ohio St.3d 462 , 2014-Ohio-5445, ¶ 230 , citation omitted, overruled in part on other grounds, State v. Bates, 159 Ohio St.3d 156 , 2020-Ohio-634 .

32016–2021
State v. Garner green
ohio · 1995
2 sentences

2025"The cumulative error doctrine is inapplicable when there are not multiple instances presented of harmless error." State v. Froman, 2022-Ohio-2726, ¶ 200 (12th Dist.), citing State v. Garner, 74 Ohio St.3d 49, 64 , 1995-Ohio-168 . {¶ 81} Here, we have found no prejudicial errors and only one harmless error— admission of Elliot's report into evidence.

2024"The cumulative error doctrine is inapplicable when there are not multiple instances presented of harmless error." State v. Froman, 2022-Ohio-2726, ¶ 200 (12th Dist.), citing State v. Garner, 74 Ohio St.3d 49, 64 , 1995-Ohio-168 (1995). {¶ 88} Here, we found, with respect to Creech's third assignment of error, that the trial court did not err when it denied Creech's request for a mistrial and that it properly instructed the jury regarding Chief Spurlock's statements about Creech's silence and request for counsel and regarding Creech's right not to testify.

22024–2025
Strickland v. Washington green
scotus · 1984
2 sentences

2024“A claim of cumulative error based on the ineffective assistance of counsel would require a determination that while no single act by trial counsel met the standard set forth in Strickland, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 , the cumulative effect of counsel’s conduct satisfied the Strickland standard.” State v. Howard, 2d Dist.

2024“A claim of cumulative error based on the ineffective assistance of counsel would require a determination that while no single act by trial counsel met the standard set forth in Strickland, 466 U.S. 668 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 , the cumulative effect of counsel’s conduct satisfied the Strickland standard.” State v. Howard, 2d Dist.

22013–2024
State v. Wilson green
· 2019
2 sentences

2023Warren No. CA2018-03-022, 2019-Ohio-338, ¶ 25 . {¶ 54} However, as relevant here, the Ohio Supreme Court has stated that "in order to consider whether ‘cumulative' error is present, [the court] would first have to find that multiple errors were committed in [the] case." State v. Madrigal, 87 Ohio St.3d 378, 398 (2000); State v. Kaufold, 12th Dist.

2021Warren No. CA2018-03-022, 2019-Ohio-338, ¶ 25 , quoting State v. Kirkland, 140 Ohio St.3d 73 , 2014-Ohio-1966, ¶ 140 .

22021–2023
State v. Bates (Slip Opinion) green
ohio · 2020
2 sentences

2021We disagree. {¶ 84} "Under the doctrine of accumulated error, a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal." State v. Pickens, 141 Ohio St.3d 462 , 2014-Ohio-5445, ¶ 230 , citation omitted, overruled in part on other grounds, State v. Bates, 159 Ohio St.3d 156 , 2020-Ohio-634 .

2021We disagree. {¶ 84} "Under the doctrine of accumulated error, a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the instances of trial-court error does not individually constitute cause for reversal." State v. Pickens, 141 Ohio St.3d 462 , 2014-Ohio-5445, ¶ 230 , citation omitted, overruled in part on other grounds, State v. Bates, 159 Ohio St.3d 156 , 2020-Ohio-634 .

22021–2021
State v. Wesson green
ohio · 2013
1 sentence

2025“The cumulative error doctrine provides that ‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.” State v. Wesson, 2013-Ohio-4575, ¶ 87 , quoting State v. Powell, 2012-Ohio-2577, ¶ 223 . {¶66} Given that we did not find multiple errors, we will not apply the cumulative-error doctrine.

12025–2025
State v. Knuff green
ohio · 2024
1 sentence

2025Law and analysis {¶67} “Under the cumulative-error doctrine, ‘a conviction will be reversed when the cumulative effect of errors in a trial deprives a defendant of a fair trial even though each of the numerous instances of trial-court error does not individually constitute cause for reversal.’ ” State v. Knuff, 2024-Ohio-902, ¶ 288 , quoting State v. Powell, 2012-Ohio-2577, ¶ 223 .

12025–2025
State v. Blanton green
ohio · 2022
12024–2024
State v. K.A.C. green
ohioctapp · 2024
12024–2024
State v. Tench (Slip Opinion) green
ohio · 2018
12021–2021
State v. Tench green
ohio · 2018
12021–2021
State v. Myers (Slip Opinion) green
ohio · 2018
12018–2018
State v. Montgomery (Slip Opinion) green
ohio · 2016
12018–2018
State v. Clinton green
ohio · 2017
12018–2018
State v. Barnes green
ohio · 2002
12017–2017
State v. Lott green
ohio · 1990
12016–2016
State v. Jones green
ohio · 2000
12016–2016
State v. Maxwell green
ohio · 2014
12016–2016
State v. Stober green
ohioctapp · 2014
12016–2016

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2903.01 (27) OH § Ohio Rev. Code § 2907.02 (26) OH § Ohio Rev. Code § 2929.04 (26) OH § Ohio Rev. Code § 2929.05 (25) OH § Ohio Rev. Code § 2903.11 (20) OH § Ohio Rev. Code § 2929.03 (20) OH § Ohio Rev. Code § 2903.02 (19) OH § Ohio Rev. Code § 2907.01 (17) OH § Ohio Rev. Code § 2905.01 (14) OH § Ohio Rev. Code § 2911.01 (14) OH § Ohio Rev. Code § 2929.14 (14) OH § Ohio Rev. Code § 2907.05 (13)

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.

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