cumulative prejudice doctrine (Utah) · Go Syfert
← Utah issues

cumulative prejudice doctrine in Utah

10 Utah opinions name it 1 courts 2013–2026 7 in the last five years

The cases below were cited by Utah 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 (5)

CaseFollowedCited
State v. Dunngreen
utah · 1993 · cited in 2 Utah opinions naming this issue, 2013–2017
2 sentences

2017“Under the doctrine of cumulative prejudice, we will reverse ‘if the cumulative effect of the several errors undermines our confidence that a fair trial was had.’” See State v. Campos, 2013 UT App 213, ¶ 61 , 309 P.3d 1160 (ellipsis omitted) (quoting State v. Dunn, 850 P.2d 1201, 1229 (Utah 1993)). “ ‘In assessing a claim of cumulative error, we consider all the identified errors, as well as any errors we assume may have occurred.’” State v. Cheek, 2015 UT App 243, ¶ 75 , 361 P.3d 679 (quoting Dunn, 850 P.2d at 1229 ).

2017“Under the doctrine of cumulative prejudice, we will reverse ‘if the cumulative effect of the several errors undermines our confidence that a fair trial was had.’” See State v. Campos, 2013 UT App 213, ¶ 61 , 309 P.3d 1160 (ellipsis omitted) (quoting State v. Dunn, 850 P.2d 1201, 1229 (Utah 1993)). “ ‘In assessing a claim of cumulative error, we consider all the identified errors, as well as any errors we assume may have occurred.’” State v. Cheek, 2015 UT App 243, ¶ 75 , 361 P.3d 679 (quoting Dunn, 850 P.2d at 1229 ).

22
State v. Cheekgreen
utahctapp · 2015 · cited in 2 Utah opinions naming this issue, 2017–2026
2 sentences

2026See State v. Cheek, 2015 UT App 243, ¶ 75 , 361 P.3d 679 . ¶55 Reversal under the cumulative prejudice doctrine requires that we “determine that (1) an error occurred, (2) the error, standing alone, has a conceivable potential for harm, and (3) the cumulative effect of all the potentially harmful errors undermines [our] confidence in the outcome.” State v. Williams, 2025 UT App 118, ¶ 38 , 576 P.3d 1142 (cleaned up), cert. denied, 581 P.3d 554 (Utah 2025).

2026See State v. Cheek, 2015 UT App 243, ¶ 75 , 361 P.3d 679 . ¶55 Reversal under the cumulative prejudice doctrine requires that we “determine that (1) an error occurred, (2) the error, standing alone, has a conceivable potential for harm, and (3) the cumulative effect of all the potentially harmful errors undermines [our] confidence in the outcome.” State v. Williams, 2025 UT App 118, ¶ 38 , 576 P.3d 1142 (cleaned up), cert. denied, 581 P.3d 554 (Utah 2025).

12
State v. Martinez-Castellanosgreen
utah · 2018 · cited in 1 Utah opinions naming this issue, 2026–2026
2 sentences

2026See State v. Martinez-Castellanos, 2018 UT 46, ¶ 48 , 428 P.3d 1038 (stating that “a single accumulable error cannot warrant reversal under the cumulative error doctrine”). 20221106-CA 43 2026 UT App 20

2026See State v. Martinez-Castellanos, 2018 UT 46, ¶ 48 , 428 P.3d 1038 (stating that “a single accumulable error cannot warrant reversal under the cumulative error doctrine”). 20221106-CA 43 2026 UT App 20

11
State v. Jamesgreen
utahctapp · 2026 · cited in 1 Utah opinions naming this issue, 2026–2026
2 sentences

2026See State v. Martinez-Castellanos, 2018 UT 46, ¶ 48 , 428 P.3d 1038 (stating that “a single accumulable error cannot warrant reversal under the cumulative error doctrine”). 20221106-CA 43 2026 UT App 20

2026It is not necessary to engage in a cumulative prejudice analysis with regard to this issue, as we did with the other two, see supra note (continued…) 20221106-CA 42 2026 UT App 20 State v. James CONCLUSION ¶107 James raises ten different claims of ineffective assistance, three based on the existing record and seven more in connection with his rule 23B motion.

11
State v. Williamsgreen
utahctapp · 2025 · cited in 1 Utah opinions naming this issue, 2026–2026
2 sentences

2026See State v. Cheek, 2015 UT App 243, ¶ 75 , 361 P.3d 679 . ¶55 Reversal under the cumulative prejudice doctrine requires that we “determine that (1) an error occurred, (2) the error, standing alone, has a conceivable potential for harm, and (3) the cumulative effect of all the potentially harmful errors undermines [our] confidence in the outcome.” State v. Williams, 2025 UT App 118, ¶ 38 , 576 P.3d 1142 (cleaned up), cert. denied, 581 P.3d 554 (Utah 2025).

2026See State v. Cheek, 2015 UT App 243, ¶ 75 , 361 P.3d 679 . ¶55 Reversal under the cumulative prejudice doctrine requires that we “determine that (1) an error occurred, (2) the error, standing alone, has a conceivable potential for harm, and (3) the cumulative effect of all the potentially harmful errors undermines [our] confidence in the outcome.” State v. Williams, 2025 UT App 118, ¶ 38 , 576 P.3d 1142 (cleaned up), cert. denied, 581 P.3d 554 (Utah 2025).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
State v. King green
utahctapp · 2017
2 sentences

2026When applying the doctrine of cumulative prejudice, we consider “the standard of review applicable to each underlying claim of error and reverse if the cumulative effect of the several errors undermines our confidence that a fair trial was had.” State v. King, 2017 UT App 43, ¶ 15 , 392 P.3d 997 (cleaned up).

2026When applying the doctrine of cumulative prejudice, we consider “the standard of review applicable to each underlying claim of error and reverse if the cumulative effect of the several errors undermines our confidence that a fair trial was had.” State v. King, 2017 UT App 43, ¶ 15 , 392 P.3d 997 (cleaned up).

42025–2026
State v. Vine green
utahctapp · 2025
2 sentences

2026Under that doctrine, “we will reverse if the cumulative effect of the several errors undermines our confidence that a fair trial was had.” State v. Vine, 2025 UT App 147 , ¶ 33 n.3, 580 P.3d 401 (quotation simplified).

2026Under that doctrine, “we will reverse if the cumulative effect of the several errors undermines our confidence that a fair trial was had.” State v. Vine, 2025 UT App 147 , ¶ 33 n.3, 580 P.3d 401 (quotation simplified).

22025–2026
State v. Campos green
utahctapp · 2013
2 sentences

2019In this case, because we have identified two instances of deficient performance, we analyze the prejudice issue in cumulative fashion, see State v. Campos, 2013 UT App 213, ¶ 61 , 309 P.3d 1160 (applying “the doctrine of cumulative prejudice” in a similar situation), with the relevant overarching question being this one: if the jury had been instructed correctly as to the burden of proof regarding self-defense, and if it had not heard the officer’s testimony and the prosecutor’s argument about Bonds’s silence while being arrested, is there a significant possibility that the result of the trial

2019In this case, because we have identified two instances of deficient performance, we analyze the prejudice issue in cumulative fashion, see State v. Campos, 2013 UT App 213, ¶ 61 , 309 P.3d 1160 (applying “the doctrine of cumulative prejudice” in a similar situation), with the relevant overarching question being this one: if the jury had been instructed correctly as to the burden of proof regarding self-defense, and if it had not heard the officer’s testimony and the prosecutor’s argument about Bonds’s silence while being arrested, is there a significant possibility that the result of the trial

22017–2019
State v. Garza green
utahctapp · 2026
1 sentence

2026But in doing so, “we leave open the possibility that, if some future case arises in which” this issue is “better presented, we may consider [it] anew.” Keisel v. Westbrook, 2023 UT App 163 , ¶ 52 n.9, 542 P.3d 536 . 20220330-CA 37 2026 UT App 128

12026–2026

Statutes the citing opinions construe

UT § Utah Code § 41-6a-210 (3) UT § Utah Code § 68-3-3 (3) UT § Utah Code § 76-2-103 (3) UT § Utah Code § 76-2-202 (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

UT 10 (2013–2026) CA 9 (2012–2025) PA 9 (2015–2026) GA 5 (2021–2026) WI 4 (2015–2023) IA 3 (2017–2025) NC 2 (2021–2021) FL 2 (2019–2022)

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.

← Caselaw search · G Cite Topics · Brief Check