Travis Campbell v. State, 382 S.W.3d 545

Campbell was convicted of aggravated assault with a deadly weapon (fork) and sentenced to four years under a State punishment agreement.
The offense arose from an alleged assault at Campbell and Ana B.'s home after a contentious Facebook message incident.
Ana testified to extensive injuries and sexual assaults; Campbell testified that injuries resulted from self-defense during a mutual altercation.
The State introduced printouts of three Facebook messages alleged to be from Campbell to Ana as State’s Exhibit 14.
Campbell challenged authentication, arguing the messages were not proven to be from his Facebook account.
The trial court admitted the Facebook messages over Campbell’s authentication objection; the jury found him guilty of aggravated assault with a deadly weapon.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Facebook messages were properly authenticated	Campbell	Campbell	Auth admissible; sufficient prima facie authentication
Whether admission of the messages affected substantial rights	Campbell	State	Harmless error; no substantial effect on verdict

Tienda v. State, 358 S.W.3d 633 (Tex. Crim. App. 2012) (authentication is a preliminary question; circumstantial evidence suffices)
Massimo v. State, 144 S.W.3d 210 (Tex. App.—Fort Worth 2004) (identifying features in electronic communications support authentication)
Manuel v. State, 357 S.W.3d 66 (Tex. App.—Tyler 2011) (proponent need only produce evidence supporting genuineness)
Doe v. MySpace, Inc., 474 F. Supp. 2d 843 (W.D. Tex. 2007) (Facebook/MySpace authentication concerns; twofold identity issue)
Commonwealth v. Purdy, 945 N.E.2d 372 (Mass. 2011) (email from defendant’s account linked by circumstantial evidence)
Griffin v. State, A.3d 421 (Md. 2011) (MySpace/Facebook authentication considerations; similar rationale)
United States v. Chin, 371 F.3d 31 (2d Cir. 2004) (limits of authentication; not required to negate all possibilities)