claim of cumulative error (Georgia) · Go Syfert
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claim of cumulative error in Georgia

10 Georgia opinions name it 2 courts 2020–2026 9 in the last five years

The cases below were cited by Georgia 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 (6)

CaseFollowedCited
O'neal v. Stategreen
ga · 2023 · cited in 5 Georgia opinions naming this issue, 2026–2026
2 sentences

2026In considering a claim of cumulative error, we “evaluate only the effects of matters determined to be error, not the cumulative effect of non-errors.” O’Neal v. State, 316 Ga. 264, 271 (2023).

2026Citing State v. Lane, 308 Ga. 10 (2020), Murphy argues that, “in weighing the prejudicial effect on Murphy’s trial, trial counsel’s deficiency is to be considered cumulatively with any errors by the trial court.” “In considering a claim of cumulative error, we evaluate only the effects of matters determined to be error, not the cumulative effect of non-errors.” O’Neal v. State, 316 Ga. 264, 271 (2023).

55
Thrift v. Stategreen
ga · 2020 · cited in 2 Georgia opinions naming this issue, 2023–2023
2 sentences

2023Thrift v. State, 310 Ga. 499, 515 (10) ( 852 SE2d 560 ) (2020) (“in order to establish a claim of cumulative error, a defendant must show . . . that at least two errors were committed in the course of the trial”) (citation and punctuation omitted). 6.

2023Thrift v. State, 310 Ga. 499, 515 (10) ( 852 SE2d 560 ) (2020) (“in order to establish a claim of cumulative error, a defendant must show . . . that at least two errors were committed in the course of the trial”) (citation and punctuation omitted). 6.

22
State v. Lanegreen
ga · 2020 · cited in 3 Georgia opinions naming this issue, 2020–2026
2 sentences

2026Citing State v. Lane, 308 Ga. 10 (2020), Murphy argues that, “in weighing the prejudicial effect on Murphy’s trial, trial counsel’s deficiency is to be considered cumulatively with any errors by the trial court.” “In considering a claim of cumulative error, we evaluate only the effects of matters determined to be error, not the cumulative effect of non-errors.” O’Neal v. State, 316 Ga. 264, 271 (2023).

2026Citing State v. Lane, 308 Ga. 10 (2020), Murphy argues that, “in weighing the prejudicial effect on Murphy’s trial, trial counsel’s deficiency is to be considered cumulatively with any errors by the trial court.” “In considering a claim of cumulative error, we evaluate only the effects of matters determined to be error, not the cumulative effect of non-errors.” O’Neal v. State, 316 Ga. 264, 271 (2023).

13
Cox v. Stategreen
ga · 2019 · cited in 1 Georgia opinions naming this issue, 2024–2024
1 sentence

2024Hodges and Watkins, JJ., concur. 19 See, e.g., Howard v. State, __ Ga. __ (2) n.2 (Case No. S24A0105, decided Mar. 19, 2024), citing Mims v. State, 310 Ga. 853 , 854 n.2 ( 854 SE2d 742 ) (2021) (“An appealing party may not use its brief to expand its enumeration of errors by arguing the incorrectness of a trial court ruling not mentioned in the enumeration of errors.”). 20 See, e.g., Cox v. State, 306 Ga. 736, 743 (2) (e) ( 832 SE2d 354 ) (2019) (explaining that if the appellate court is reviewing a claim of cumulative error in the context of ineffective assistance of counsel, the court should

11
Mims v. Stategreen
ga · 2021 · cited in 1 Georgia opinions naming this issue, 2024–2024
2 sentences

2024Hodges and Watkins, JJ., concur. 19 See, e.g., Howard v. State, __ Ga. __ (2) n.2 (Case No. S24A0105, decided Mar. 19, 2024), citing Mims v. State, 310 Ga. 853 , 854 n.2 ( 854 SE2d 742 ) (2021) (“An appealing party may not use its brief to expand its enumeration of errors by arguing the incorrectness of a trial court ruling not mentioned in the enumeration of errors.”). 20 See, e.g., Cox v. State, 306 Ga. 736, 743 (2) (e) ( 832 SE2d 354 ) (2019) (explaining that if the appellate court is reviewing a claim of cumulative error in the context of ineffective assistance of counsel, the court should

2024Hodges and Watkins, JJ., concur. 19 See, e.g., Howard v. State, __ Ga. __ (2) n.2 (Case No. S24A0105, decided Mar. 19, 2024), citing Mims v. State, 310 Ga. 853 , 854 n.2 ( 854 SE2d 742 ) (2021) (“An appealing party may not use its brief to expand its enumeration of errors by arguing the incorrectness of a trial court ruling not mentioned in the enumeration of errors.”). 20 See, e.g., Cox v. State, 306 Ga. 736, 743 (2) (e) ( 832 SE2d 354 ) (2019) (explaining that if the appellate court is reviewing a claim of cumulative error in the context of ineffective assistance of counsel, the court should

11
Bulloch v. Stategreen
ga · 2013 · cited in 1 Georgia opinions naming this issue, 2023–2023
2 sentences

2023In considering a claim of cumulative error, we “evaluate only the effects of matters determined to be error, not the cumulative effect of non-errors.” (Citation and punctuation omitted.) Bulloch v. State, 293 Ga. 179, 183 (2) (744 SE2d 763) (2013).

2023In considering a claim of cumulative error, we “evaluate only the effects of matters determined to be error, not the cumulative effect of non-errors.” (Citation and punctuation omitted.) Bulloch v. State, 293 Ga. 179, 183 (2) (744 SE2d 763) (2013).

11

Distinguished, questioned or overruled (0)

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

Statutes the citing opinions construe

GA § 24-8-807 (3) GA § 5-5-20 (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

CA 103 (2012–2026) FL 88 (2004–2026) NV 46 (1998–2024) OH 28 (2007–2025) WY 22 (1990–2020) UT 19 (2001–2026) MI 16 (2016–2026) KS 14 (2016–2025) MS 11 (1997–2025) GA 10 (2020–2026) NM 8 (1974–2010) IL 6 (1999–2026) PA 6 (2018–2021) MN 4 (2018–2024) TX 4 (1993–2024) AR 3 (2003–2025) SD 3 (2019–2020) MO 3 (2007–2017) IA 3 (2014–2026) WA 2 (2018–2018) ME 2 (2019–2024)

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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