The following excerpt is from Hein v. Sullivan, 601 F.3d 897 (9th Cir. 2010):
Petitioners' next claim is that "the cumulative effect of multiple errors" prejudiced them. Jackson, 513 F.3d at 1085 (internal quotation marks omitted) (quoting Whelchel v. Washington, 232 F.3d 1197, 1212 (9th Cir.2000)). As with petitioners' prosecutorial misconduct claims, we consider whether the cumulative error "so infected the trial with unfairness as to make the resulting conviction a denial of due process." Donnelly, 416 U.S. at 643, 94 S.Ct. 1868.
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