Chamberlain v. State

In Chamberlain v. State, 998 S.W.2d 230, 238 (Tex. Crim. App. 1999), the Texas Court of Criminal Appeals stated that it was unaware of any authority that non-errors may in their cumulative effect cause error. Id. at 238. The Chamberlain court did acknowledge that it was conceivable that a number of errors may be found harmful in their cumulative effect. Id. In doing so, the court cited Stahl v. State, 749 S.W.2d 826, 832 (Tex. Crim. App. 1988) (holding harm lies in the cumulative effect of the outburst and the improper arguments).