Butler v. Texas (original by judge yeary)
Annotate this CaseAppellant was convicted of the aggravated kidnapping of his girlfriend, Ashley Salas. On direct appeal, he complained that the trial court admitted certain text messages into evidence that Appellant claimed were not properly authenticated. The State introduced the text messages through Salas, who testified that she recognized Appellant’s phone number displayed on the text messages, that the text messages were from Appellant, and that Appellant even called her from that phone number at some point during the course of their text messaging back and forth. Relying upon the Court of Criminal Appeals' opinion in "Tienda v. Texas," (358 S.W.3d 633 (Tex. Crim. App. 2012)), the Court of Appeals held that Salas’s testimony did not adequately serve to authenticate the text messages. Finding that the trial court erred by admitting the text messages and that their admission into evidence was not harmless, the court of appeals reversed Appellant’s conviction. The Court of Criminal Appeals concluded the Court of Appeals erred in its application of the Tienda holding, and reversed.
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