493 Washington opinions name it 2 courts 1981–2026 180 in the last five years
The cases below were cited by Washington 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. Webergreen2 sentences2025The cumulative error doctrine “does not apply where the errors are few and have little or no effect on the outcome of the trial.” State v. Weber, 159 Wn.2d 252, 279 , 149 P.3d 646 (2006). 2024“Cumulative error may warrant reversal, even if each error standing alone would otherwise be considered harmless.” State v. Weber, 159 Wn.2d 252, 279 , 149 P.3d 646 (2006). | 8 | 108 |
State v. Webergreen2 sentences2026However, the cumulative error doctrine does not apply if there were minimal errors and they had “little or no effect on the outcome of trial.” - 28 - No. 86447-5-I/29 Id. 2025The cumulative error doctrine “does not apply where the errors are few and have little or no effect on the outcome of the trial.” State v. Weber, 159 Wn.2d 252, 279 , 149 P.3d 646 (2006). | 8 | 102 |
State v. Emerygreen2 sentences2026“Under the cumulative error doctrine, a defendant may be entitled to a new trial when cumulative errors produce a trial that is fundamentally unfair.” Emery, 174 Wn.2d at 766 . 2026“Under the cumulative error doctrine, a defendant may be entitled to a new trial when cumulative errors produce a trial that is fundamentally unfair.” State v. Emery, 174 W.2d 741 , 766, 278 P.3d 653 (2012). “[T]he defendant must show that the combined effect of multiple errors requires a new trial.” State v. Cecil, 34 - 23 - No. 87273-7-I/24 (consol. with No. 87274-5-I) Wn. | 4 | 62 |
DeHeer v. Seattle Post-Intelligencergreen2 sentences2020App. 907, 911 , 10 P.3d 504 (2000) (“Where no authorities are cited in support of a proposition, the court is not required to search out authorities, but may assume that counsel, after diligent search, has found none.”) (quoting DeHeer v. Seattle Post-Intelligencer, 60 Wn.2d 122, 126 , 372 P.2d 193 (1962)). 21 No. 78964-3-I/22 reversal. 44 Even when this court decides that each error standing alone would otherwise be harmless, cumulative error may warrant this court's reversal of a trial court decision. 45 But, if the errors are few and do not affect the trial's outcome, a court will not find 2020App. 907, 911 , 10 P.3d 504 (2000) (“Where no authorities are cited in support of a proposition, the court is not required to search out authorities, but may assume that counsel, after diligent search, has found none.”) (quoting DeHeer v. Seattle Post-Intelligencer, 60 Wn.2d 122, 126 , 372 P.2d 193 (1962)). 21 No. 78964-3-I/22 reversal. 44 Even when this court decides that each error standing alone would otherwise be harmless, cumulative error may warrant this court's reversal of a trial court decision. 45 But, if the errors are few and do not affect the trial's outcome, a court will not find | 3 | 4 |
State v. Greiffgreen2 sentences2026The cumulative error doctrine is applied in “instances when there have been several trial errors that standing alone may not be sufficient to justify reversal but when combined may deny a defendant a fair trial.” State v. Greiff, 141 Wn.2d 910, 929 , 10 P.3d 390 (2000). 2026The cumulative error doctrine is applied in “instances when there have been several trial errors that standing alone may not be sufficient to justify reversal but when combined may deny a defendant a fair trial.” State v. Greiff, 141 Wn.2d 910, 929 , 10 P.3d 390 (2000). | 2 | 122 |
State v. Greiffgreen2 sentences2026The cumulative error doctrine is applied in “instances when there have been several trial errors that standing alone may not be sufficient to justify reversal but when combined may deny a defendant a fair trial.” State v. Greiff, 141 Wn.2d 910, 929 , 10 P.3d 390 (2000). 2026The cumulative error doctrine is applied in “instances when there have been several trial errors that standing alone may not be sufficient to justify reversal but when combined may deny a defendant a fair trial.” State v. Greiff, 141 Wn.2d 910, 929 , 10 P.3d 390 (2000). | 2 | 120 |
State v. KARLOWgreen2 sentences2026CUMULATIVE ERROR Bowers also argues that the cumulative error doctrine warrants reversal and remand for a new trial because the errors he alleged, in total, denied him the right to a fair trial. “[A] defendant may be entitled to a new trial when cumulative errors produce a trial that is fundamentally unfair.” State v. Emery, 174 Wn.2d 741, 766 , 278 P.3d 653 (2012). 2026“Under the cumulative error doctrine, a defendant may be entitled to a new trial when cumulative errors produce a trial that is fundamentally unfair.” State v. Emery, 174 W.2d 741 , 766, 278 P.3d 653 (2012). “[T]he defendant must show that the combined effect of multiple errors requires a new trial.” State v. Cecil, 34 - 23 - No. 87273-7-I/24 (consol. with No. 87274-5-I) Wn. | 2 | 33 |
In re the Personal Restraint of Yatesgreen2 sentences2020Restraint of Yates, 177 Wn.2d 1 , 65–66, 296 P.3d 872 (2013) (quoting In re Det. 2020See Yates, 177 Wn.2d at 65-66 . | 2 | 5 |
State v. Hodgesgreen2 sentences2024“The cumulative error doctrine applies only when several trial errors occurred which, standing alone, may not be sufficient to justify a reversal, but when combined together, may deny a defendant a fair trial.” State v. Hodges, 118 Wn. 2024“The cumulative error doctrine applies only when several trial errors occurred which, standing alone, may not be sufficient to justify a reversal, but when combined together, may deny a defendant a fair trial.” State v. Hodges, 118 Wn. | 1 | 40 |
In re the Detention of Coegreen2 sentences2026“The cumulative error doctrine applies where a combination of trial errors denies the accused a fair trial, even where any one of the errors, taken individually, may not justify reversal.” In re Det. of Coe, 175 Wn.2d 482, 515 , 286 P.3d 29 (2012). 2026“The cumulative error doctrine applies where a combination of trial errors denies the accused a fair trial, even where any one of the errors, taken individually, may not justify reversal.” In re Det. of Coe, 175 Wn.2d 482, 515 , 286 P.3d 29 (2012). | 1 | 30 |
In re the Personal Restraint of Crossgreen2 sentences2024“There is no prejudicial error under the cumulative error rule if the evidence is overwhelming against a defendant.” Cross, 180 Wn.2d at 691 . 2022Restraint of Cross, 180 Wn.2d 664, 690 , 327 P.3d 660 (2014) (“The cumulative error doctrine applies where a combination of trial errors denies the accused of a fair trial, even where any one of the errors, taken individually, would be harmless.”), abrogated on other grounds by State v. Gregory, 192 Wn.2d 1 , 427 P.3d 621 (2018). | 1 | 19 |
State v. Davisred2 sentences2016While errors that do not individually require reversal may still collectively deny a defendant a fair trial under the cumulative error doctrine, State v. Davis. 175 Wash.2d at 287, 345, 28 Ex. 14. 17 No. 73945-0-1/18 290 P.3d 43 (2012). 2016While errors that do not individually require reversal may still collectively deny a defendant a fair trial under the cumulative error doctrine, State v. Davis. 175 Wash.2d at 287, 345, 28 Ex. 14. 17 No. 73945-0-1/18 290 P.3d 43 (2012). | 1 | 10 |
State v. Thorgersongreen2 sentences2020We disagree. ‘Cumulative error may call for reversal, even if each error standing alone would be considered harmless.” Thorgerson, 172 Wn.2d at 454 (citing State v. Weber, 159 Wn.2d 252, 279 , 149 P.3d 646 (2006)). 2020See, e.g., Thorgerson, 172 Wn.2d at 442-44, 454 (reviewing multiple claims of prosecutorial misconduct individually and, despite finding some improper, declining to apply the cumulative error doctrine). | 1 | 6 |
State v. Yarbroughgreen2 sentences2024See, e.g., Emery, 174 Wn.2d 741, 766 , 278 P.3d 653 (2012); State v. Yarbrough, 151 Wn. 2014The cumulative error doctrine applies where " there have been several trial errors that standing alone may not be sufficient to justify reversal but when combined may deny a defendant a fair trial." State v. Greiff, 141 Wn.2d 910, 929 , 10 P. 3d 390 ( 2000). " The defendant bears the burden of proving an accumulation of error of sufficient magnitude that retrial is necessary." State v. Yarbrough, 151 Wn. | 1 | 5 |
| State v. Alexandergreen | 1 | 3 |
| State v. Saundersgreen | 1 | 2 |
| State v. Racusgreen | 1 | 1 |
| State Of Washington, V. Troy C. Restvedtgreen | 1 | 1 |
| State v. Iversongreen | 1 | 1 |
| State v. Elmoregreen | 1 | 1 |
| State v. Elmoregreen | 1 | 1 |
| State v. Logangreen | 1 | 1 |
| State v. Logangreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Clark
green
2 sentences2026Under the cumulative error doctrine, a defendant “must show that while multiple trial errors, ‘standing alone, might not be of sufficient gravity to constitute grounds for a new trial, the combined effect of the accumulation of errors most certainly requires a new trial.’ ” State v. Clark, 187 Wn.2d 641, 649 , 389 P.3d 462 (2017) (quoting State v. Coe, 101 Wn.2d 772, 789 , 684 P.2d 668 (1984)). 2026Under the cumulative error doctrine, a defendant “must show that while multiple trial errors, ‘standing alone, might not be of sufficient gravity to constitute grounds for a new trial, the combined effect of the accumulation of errors most certainly requires a new trial.’ ” State v. Clark, 187 Wn.2d 641, 649 , 389 P.3d 462 (2017) (quoting State v. Coe, 101 Wn.2d 772, 789 , 684 P.2d 668 (1984)). | 46 | 2019–2026 |
State v. Venegas
green
2 sentences2025Under the cumulative error doctrine, we may reverse a defendant’s conviction when the combined effect of errors during trial effectively denied him his right to a fair trial, “even if each error standing alone would be harmless.” State v. Venegas, 155 Wn. 2024“Under the cumulative error doctrine, we may reverse a defendant’s conviction - 13 - No. 84765-1-I/14 when the combined effect of errors during trial effectively denied the defendant [the] right to a fair trial even if each error standing alone would be harmless.” State v. Venegas, 155 Wn. | 30 | 2011–2025 |
State v. Coe
green
2 sentences2026Under the cumulative error doctrine, a defendant “must show that while multiple trial errors, ‘standing alone, might not be of sufficient gravity to constitute grounds for a new trial, the combined effect of the accumulation of errors most certainly requires a new trial.’ ” State v. Clark, 187 Wn.2d 641, 649 , 389 P.3d 462 (2017) (quoting State v. Coe, 101 Wn.2d 772, 789 , 684 P.2d 668 (1984)). 2026Under the cumulative error doctrine, a defendant “must show that while multiple trial errors, ‘standing alone, might not be of sufficient gravity to constitute grounds for a new trial, the combined effect of the accumulation of errors most certainly requires a new trial.’ ” State v. Clark, 187 Wn.2d 641, 649 , 389 P.3d 462 (2017) (quoting State v. Coe, 101 Wn.2d 772, 789 , 684 P.2d 668 (1984)). | 21 | 2009–2026 |
State v. Venegas
green
2 sentences2025App. 507, 520 , 228 P.3d 813 (2010). 2024App. -28- No. 83638-2-I/29 507, 520, 228 P.3d 813 (2010). | 21 | 2011–2025 |
State v. Hodges
green
2 sentences2025App. 668, 673-74 , 77 P.3d 375 (2003) (the cumulative error doctrine applies only when combined trial court errors may deny a defendant a fair trial). 2008App. 668, 673-74 , 77 P.3d 375 (2003). ¶65 We hold that the cumulative error doctrine does not apply here. | 14 | 2005–2025 |
State Of Washington, V. Heather Azevedo
green
2 sentences2026App. 2d 70 , 85, 547 P.3d 287 (2024) (quoting In re Pers. 2026App. 2d 70 , 85, 547 P.3d 287 (2024) (quoting In re Pers. | 11 | 2024–2026 |
State v. Lazcano
green
2 sentences2026State v. Lazcano, 188 Wn. 2021Accordingly, we accept the State’s concession and remand for resentencing on this count. 4 The offender score was 0 on count III, so that count is unaffected. 32 No. 54241-2-II STATEMENT OF ADDITIONAL GROUNDS FOR REVIEW A. Cumulative Error Under the cumulative error doctrine, the defendant may be entitled to a new trial where “multiple errors combine to deny the defendant a fair trial.” State v. Lazcano, 188 Wn. | 9 | 2016–2026 |
State v. Jackson
green
2 sentences2021App. 877, 889 , 209 P.3d 553 9 This instruction followed the Washington Pattern Jury Instruction: A person is entitled to act on appearances in defending [himself] [herself] [another], if [he] [she] believes in good faith and on reasonable grounds that [he] [she] [another] is in actual danger of injury, although it afterwards might develop that the person was mistaken as to the extent of the danger. 2021App. 877, 889 , 209 P.3d 553 (2009). | 9 | 2015–2021 |
State v. Jackson
green
2 sentences2021“The cumulative error doctrine applies when several trial errors occurred and none alone warrants reversal but the combined errors effectively denied the defendant of a fair trial.” State v. Jackson, 150 Wn. 2021“The cumulative error doctrine applies when several trial errors occurred and none alone warrants reversal but the combined errors effectively denied the defendant a fair trial.” State v. Jackson, 150 Wn. | 9 | 2015–2021 |
State v. Gregory
green
2 sentences2024Restraint of Cross, 180 Wn.2d 664, 690 , 327 P.3d 660 (2014), abrogated on other grounds by State v. Gregory, 192 Wn.2d 1 , 427 P.3d 621 (2018). 2022Restraint of Cross, 180 Wn.2d 664, 690 , 327 P.3d 660 (2014) (“The cumulative error doctrine applies where a combination of trial errors denies the accused of a fair trial, even where any one of the errors, taken individually, would be harmless.”), abrogated on other grounds by State v. Gregory, 192 Wn.2d 1 , 427 P.3d 621 (2018). | 8 | 2019–2024 |
Weber v. Washington
green
2 sentences2023State v. Weber, 159 Wn.2d 252, 279 , 149 P.3d 646 (2006), cert. denied, 551 U.S. 1137 (2007). 2020“Cumulative error may warrant reversal, even if each error standing alone would otherwise be considered harmless.” State v. Weber, 159 Wn.2d 252, 279 , 149 P.3d 646 (2006), cert. denied, 551 U.S. 1137 (2007). | 7 | 2012–2023 |
State v. Russell
green
2 sentences2018State v. Russell, 125 Wn.2d 24, 93 , 882 P.2d 747 (1994), cert denied 514 U.S. 1129 (1995). 2018State v. Russell, 125 Wn.2d 24, 93 , 882 P.2d 747 (1994), cert denied 514 U.S. 1129 (1995). | 7 | 1999–2018 |
In re the Personal Restraint of Morris
green
2 sentences2026Restraint of Morris, 176 Wn.2d 157, 172 , 288 P.3d 1140 (2012) (quoting State v. Greiff, 141 Wn.2d 910, 929 , 10 P.3d 390 (2000)). 2026Restraint of Morris, 176 Wn.2d 157, 172 , 288 P.3d 1140 (2012) (quoting State v. Greiff, 141 Wn.2d 910, 929 , 10 P.3d 390 (2000)). | 4 | 2018–2026 |
In re the Detention of McGary
green
2 sentences2025Later, this court held that because “this amendment did not take effect until after [the defendant’s ]sentencing, it applies to [the defendant] because this case is on direct 14 Bellerouche also briefly alludes to the cumulative error doctrine, which “applies when several errors occurred during trial that would not merit reversal standing alone, but together effectively denied the defendant a fair trial.” In re Det. of McGray, 175 Wn. 2025Later, this court held that because “this amendment did not take effect until after [the defendant’s ]sentencing, it applies to [the defendant] because this case is on direct 14 Bellerouche also briefly alludes to the cumulative error doctrine, which “applies when several errors occurred during trial that would not merit reversal standing alone, but together effectively denied the defendant a fair trial.” In re Det. of McGray, 175 Wn. | 4 | 2024–2025 |
Matter of Personal Restraint of Lord
green
2 sentences2020The cumulative error doctrine applies when a combination of trial errors denies the accused a fair trial, though one of the errors alone would not warrant 39 Matter of Personal Restraint of Lord, 123 Wn. 2d 296, 306 , 868 P.2d 835 (1994). 40 United States v. Gagnon, 470 U.S. 522, 526 , 105 S.Ct. 1482 , 84 L.Ed. 2d 486 (1985) (quoting Snyder v. Commonwealth of Mass., 291 U.S. 97 , 54 S.Ct. 330 , 78 L.Ed. 674 , 90 A.L.R. 575 (1934)). 41 United States v. Williams, 455 F.2d 361 (9th Cir. 1972). 42 People v. Dokes, 79 N.Y.2d 656 , 584 N.Y.S.2d 761 , 595 N.E.2d 836 (1992). 43 State v. Logan, 102 Wn. 2020The cumulative error doctrine applies when a combination of trial errors denies the accused a fair trial, though one of the errors alone would not warrant 39 Matter of Personal Restraint of Lord, 123 Wn. 2d 296, 306 , 868 P.2d 835 (1994). 40 United States v. Gagnon, 470 U.S. 522, 526 , 105 S.Ct. 1482 , 84 L.Ed. 2d 486 (1985) (quoting Snyder v. Commonwealth of Mass., 291 U.S. 97 , 54 S.Ct. 330 , 78 L.Ed. 674 , 90 A.L.R. 575 (1934)). 41 United States v. Williams, 455 F.2d 361 (9th Cir. 1972). 42 People v. Dokes, 79 N.Y.2d 656 , 584 N.Y.S.2d 761 , 595 N.E.2d 836 (1992). 43 State v. Logan, 102 Wn. | 4 | 2016–2020 |
State v. Garcia
green
2 sentences2023Again, “the trial court is in the best position to discern prejudice.” Garcia, 177 Wn. 2015Garcia, 177 Wn. | 3 | 2014–2023 |
| State v. Ramirez green | 3 | 2019–2020 |
| State v. Benn green | 3 | 1994–2020 |
| Hittson v. Georgia green | 3 | 2016–2018 |
| State v. Pellum neutral | 3 | 2009–2010 |
| Quadrant Corp. v. American States Ins. Co. neutral | 3 | 2009–2010 |
| State v. Stith green | 2 | 2025–2025 |
| State Of Washington, V. Alejandro Samuel Meza neutral | 2 | 2025–2025 |
| State v. Venegas green | 2 | 2022–2022 |
| State v. Blake green | 2 | 2021–2022 |
| State Of Washington v. Song Wang green | 2 | 2021–2021 |
| Osman v. Schmidt (In re E.G.S.) neutral | 2 | 2019–2020 |
| Deutsche Bank Nat'l Trust Co. v. Shields neutral | 2 | 2019–2020 |
| Storey v. Storey neutral | 2 | 2014–2019 |
| State v. Walker green | 2 | 2014–2017 |
| State v. Johnson green | 2 | 1999–2016 |
| Mich. Beer & Wine Wholesalers Ass'n v. Am. Beverage Ass'n green | 2 | 2015–2015 |
| State v. Cofield green | 2 | 2014–2014 |
| State v. Whalon green | 2 | 2009–2009 |
| State v. Badda green | 2 | 2009–2009 |
| State v. Newbern green | 2 | 2009–2009 |
| State v. Dhaliwal green | 2 | 2008–2008 |
| State v. Furman green | 2 | 2008–2008 |
| State v. Pirtle green | 2 | 2008–2008 |
| State v. Dhaliwal green | 2 | 2008–2008 |
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.