Does the cumulative error doctrine apply to ineffective assistance of counsel claims?

QUESTION PRESENTED 1. Does the cumulative error doctrine in the context of an ineffective assistance of counsel claim apply whereby individual errors, insufficient to necessitate a new trial, may in the aggregate deny a petitioner his right to a fair trial and his right to the effective assistance of ; counsel (Sixth Amendment) and to due process of law (Fourteenth Amendment)? Various Circuit Courts of Appeal claim that this Honorable Court has never addressed this particular claim, making it an issue of first impression. The lack of any guidance on this claim from this Court has resulted in disparate treatment of such claims by the various circuit courts, with one circuit court holding this claim is not cognizable in a federal petition. eee i