# Schmunk v. State

> Wyoming Supreme Court · February 13, 1986 · 714 P.2d 724

URL: https://www.frixlaw.com/law-library/cases/9539621

## Case

- **Full name:** Robert F. SCHMUNK, Appellant (Defendant), v. the STATE of Wyoming, Appellee (Plaintiff)
- **Court:** Wyoming Supreme Court
- **Decided:** February 13, 1986
- **Citations:** 714 P.2d 724; 1986 Wyo. LEXIS 482
- **Precedential status:** Published
- **Opinion:** Concurrence by Brown
- **Judges:** Brown, Cardine, Rooney, Rose, Thomas
- **Cited by:** 73 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9539621

## How later opinions describe it (automated extraction)

- emphasizing the unique qualities of videotapes

## Opinion text

BROWN, Justice,
concurring.
I agree that this case must be reversed.
In the last paragraph of the majority opinion, reference is made to cumulative error. It seems that the doctrine of cumulative error, in simple terms, is that several small errors add up to a big error; and while none of the small errors standing alone is sufficient for reversal, the sum of the small errors becomes substantial mandating reversal. I have a continuing problem with the nebulous doctrine of cumulative error and do not believe it has application here. The errors in this case, standing alone, are sufficient to justify reversal without resorting to cumulative error.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9539621. Public record. Not legal advice.