Ronald Bryce Hall v. State, 01-15-00568-CR

Background

Police used a confidential informant to arrange two controlled buys at Hall’s residence; informant reported purchasing meth from Hall in the first buy and from Greene in the second.
An evidentiary search warrant was issued for Hall’s residence; police executed it and found 6.3 grams of meth within arm’s reach of Hall, a pink case containing >50 small baggies, scales, syringes, a 100‑gram weight, multiple cell phones, small-cash, and a drug ledger in another bedroom.
Hall was charged with possession with intent to deliver in a drug‑free zone; a jury convicted him and assessed 20 years’ imprisonment.
On appeal Hall asserted ineffective assistance of trial counsel for failing to object to: (1) testimony about regional meth trafficking/societal effects, (2) photos on Hall’s cell phone, (3) admission of the drug ledger, and (4) admission of the search warrant and affidavit (Confrontation Clause/hearsay).
The trial court denied motions to disclose the informant’s identity and to suppress the warrant; counsel made some objections at trial but did not make Confrontation Clause/hearsay objections to the affidavit.
The Court of Appeals reviewed counsel’s performance under Strickland and considered whether objections would have been sustained and whether Hall was prejudiced by any deficiency.

Issues

Issue	Hall’s Argument	State’s Argument	Held
Admission of testimony about meth trafficking and societal effects	Counsel was ineffective for not objecting to irrelevant, prejudicial testimony	Testimony was not strongly harmful; counsel may have declined to object for strategy or to elicit sympathy	No ineffective assistance — strategic non‑objection plausible
Admission/search of cell phone and photos	Counsel ineffective for not objecting to insufficient probable cause and prejudice of photos	Affidavit linked controlled buys by phone and officer’s expertise supported probable cause; counsel did object to photos at trial	No ineffective assistance — affidavit supported probable cause; objections to photos were made and overruled
Admission of drug ledger	Counsel ineffective for failing to object to lack of authentication and that ledger was a "personal writing" exempt from evidentiary warrant	Ledger found in house, contents matched transactions, officer testimony supported authentication; ledger was business rather than personal writing	No ineffective assistance — ledger sufficiently authenticated and not protected
Admission of search warrant affidavit (Confrontation/hearsay)	Counsel ineffective for failing to object on Confrontation Clause and hearsay grounds to informant statements in affidavit	Defense strategy might have been to avoid highlighting affidavit; but affidavit strongly undermined user‑only defense by recounting first buy with Hall	Counsel deficient for not objecting; but no prejudice — abundant other evidence of intent to deliver made different outcome unlikely

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard)
Butler v. State, 459 S.W.3d 595 (authentication threshold in jury trials)
Tienda v. State, 358 S.W.3d 633 (preliminary authentication and jury determination)
Baldwin v. State, 278 S.W.3d 367 (probable cause for evidentiary search warrants defined)
Langham v. State, 305 S.W.3d 568 (Confrontation Clause and informant statements)
United States v. Wake, 948 F.2d 1422 (circumstantial evidence sufficient to authenticate drug ledgers)
United States v. Jackson, 636 F.3d 687 (authentication concerns for ledgers produced under suspect circumstances)