Ronnie Decourtland Bass, Jr. v. State, 05-13-00518-CR

Bass, Jr. was convicted of capital murder of a child under six; punishment life imprisonment.
On appeal, Bass argues the MetroPCS text messages were illegally obtained and required a warrant.
Trial sought to admit MetroPCS records including text messages; a hearing occurred and the officer testified; objections were overruled.
Text messages from the victim and co-actor’s phones were also admitted and readable; Bass lacked standing to challenge those records.
The court applied rule 44.2(a) constitutional harm analysis and found the MetroPCS records did not contribute to the conviction; the same content appeared on other phones.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of MetroPCS text messages without a warrant violated the Fourth Amendment	Bass contends warrant required; records unlawfully obtained	State contends no reversible error; other admissible texts supported trial	No harm; admission did not contribute to conviction

Cameron v. State, 241 S.W.3d 15 (Tex. Crim. App. 2007) (abuse-of-discretion review for admissibility of evidence; Rule 44.2(a) harm analysis)
Hernandez v. State, 60 S.W.3d 106 (Tex. Crim. App. 2001) (constitutional error requires reversal unless harmless beyond reasonable doubt)
Rubio v. State, 241 S.W.3d 1 (Tex. Crim. App. 2007) (assessing whether error contributed to the conviction)
Mosley v. State, 983 S.W.2d 249 (Tex. Crim. App. 1998) (harm analysis for constitutional errors)
Langham v. State, 305 S.W.3d 568 (Tex. Crim. App. 2010) (whether error affected the integrity of the process)
Scott v. State, 227 S.W.3d 670 (Tex. Crim. App. 2007) (guides harm analysis under Rule 44.2(a))
Kothe v. State, 152 S.W.3d 54 (Tex. Crim. App. 2004) (standing/privacy interest limits on challenge to third-party records)