The following excerpt is from Johnson v. Soto, No. 2:12-cv-2887 MCE DAD P (E.D. Cal. 2015):
The cumulative error doctrine in habeas recognizes that, "even if no single error were prejudicial, where there are several substantial errors, 'their cumulative effect may nevertheless be so prejudicial as to require reversal.'" Killian v. Poole, 282 F.3d 1204, 1211 (9th Cir. 2002)
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