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State v. McKnight - 2008-Ohio-2435 (Ct. App.)


The cumulative error doctrine holds that a judgment may be reversed if the cumulative effect of multiple harmless errors deprives a defendant of his constitutional rights, even though the errors individually may not rise to the level of prejudicial error. If, however, a reviewing court finds no prior instances of error, then the doctrine has no application. 


On December 9, 2000, law enforcement officers discovered the body of Emily Murray, a missing Kenyon College student, wrapped in a rug located in the back bedroom of defendant McKnight's trailer. Officers also discovered the skeletal remains of Gregory Julious, who had been missing since May 12, 2000, in a cistern located on McKnight's property. In 2002, a jury convicted McKnight of aggravated murder, kidnapping, aggravated robbery, and murder. It then recommended that the court sentence him to death. The trial court accepted the jury's recommendation and sentenced McKnight to death. McKnight filed a post-conviction relief petition, which was denied by the court without an evidentiary hearing. Subsequently, McKnight appealed the trial court's denial of his post-conviction relief petition without an evidentiary hearing. On appeal, McKnight contended that the trial court erred by adopting the state's findings of fact and conclusions of law.


Did the trial court err in its decision to deny McKnight’s petition for post-conviction relief?




The appellate court held that the trial court did not violate the inmate’s due process rights because he failed to demonstrate prejudice resulting from the trial court's adoption of the State's proposed findings of fact and conclusions of law. The State's proposed findings of fact and conclusions of law were sufficiently accurate, and there was no evidence that the trial court failed to review and consider the petition in its entirety. 

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