Cumulative Error Analysis

Under a cumulative error analysis, we determine "whether the overall effect of multiple errors amounts to prejudice." Commonwealth v. Camacho, 2002 MP 6 P 23, 6 N. Mar. I. 382; see also United States v. Rivera, 900 F.2d 1462, 1470 (10th Cir. 1990) (stating that under a cumulative error analysis, a court aggregates all errors that, standing alone, may be harmless, and "analyzes whether their cumulative effect on the outcome of the trial is such that collectively they can no longer be determined to be harmless"). In Camacho, we stated that "in some cases, although no single trial error examined in isolation is sufficiently prejudicial to warrant reversal, the cumulative effect of multiple errors may still prejudice a defendant." Id. P 120. In such instances, we determined that a "'balkanized, issue-by-issue harmless error review' is far less effective than analyzing the overall effect of all the errors in the context of the evidence introduced at trial against the defendant." Id. (quoting United States v. Frederick, 78 F.3d 1370,