The following excerpt is from United States v. Flores, 802 F.3d 1028 (9th Cir. 2015):
Flores contends that, because the prosecution committed multiple errors, we should not conduct a balkanized, issue-by-issue harmless error review. United States v. Frederick, 78 F.3d 1370, 1381 (9th Cir.1996). We agree that we must consider the cumulative effect of the errors, if any. However, Flores did not object to any of the prosecution's conduct that we find improper, so we review for plain error, not harmless error as Flores suggests.
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