Michael Meggs v. State, 438 S.W.3d 143

Portis was murdered in his apartment; two men entered, shots fired, and blood covered a large area.
Meggs appeared at a hospital with a gunshot wound and his pants were collected as evidence.
Pants and underwear were submitted for DNA testing; Portis’s DNA matched a blood stain on Meggs’s pants.
Meggs was charged with capital murder; he pleaded not guilty.
DNA testing on bandanna and baseball cap recovered at the scene also matched Meggs’s DNA.
Meggs conceded at trial that he was present at the scene; trial court denied his motion to suppress the pants’ DNA evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the denial of the suppression motion harmless error?	Meggs argues the DNA on his pants was the sole incriminating link.	State contends the error, if any, was harmless given other evidence.	Yes, harmless beyond a reasonable doubt.
Is there a basis to assess $259 in court costs?	Bill of costs not proper under Article 103.001; JIMS printout not signed.	JIMS bill met statutory requirements; proper certification.	Yes, basis for $259 court costs exists.

Hernandez v. State, 60 S.W.3d 106 (Tex. Crim. App. 2001) (harmless-error review for constitutional errors)
Neal v. State, 256 S.W.3d 264 (Tex. Crim. App. 2008) (harmless error when other evidence links defendant)
Nonn v. State, 117 S.W.3d 874 (Tex. Crim. App. 2003) (harmless error when evidence is substantially similar to other evidence)
Dowthitt v. State, 931 S.W.2d 244 (Tex. Crim. App. 1996) (evidence tying defendant to crime; harmfulness assessment)
Davis v. State, 203 S.W.3d 845 (Tex. Crim. App. 2006) (cumulative but admissible DNA evidence)
Jeffley v. State, 38 S.W.3d 847 (Tex. App.—Houston [14th Dist.] 2001) (paper on limited weight of potentially inadmissible evidence)
Johnson v. State, 423 S.W.3d 385 (Tex. Crim. App. 2014) (procedure for reviewing court-costs on appeal)
Cardenas v. State, 423 S.W.3d 396 (Tex. Crim. App. 2014) (due-process notice for mandatory-cost statutes)