Will Robert Claud Steinmann v. State, 10-16-00137-CR

Defendant Will Steinmann lived with Heather and her daughter H.P.; Steinmann was accused and convicted of indecency with a child for touching H.P. and was sentenced to 13 years.
After an initial disclosure and a first interview in which H.P. was coached to lie, a later interview revealed the inappropriate touching; Heather had encouraged H.P. to blame someone else.
At trial the State introduced: (1) a recorded jail call between Heather and Steinmann (redacted on defense objection), (2) a photograph allegedly from Steinmann’s Facebook, and (3) testimony from Detective Earles and Dr. Randy Smith including a written forensic report.
Steinmann objected at trial to the jail call (relevance/hearsay/prejudice), to authentication of the Facebook photo, and to certain testimonial statements as hearsay; some objections were sustained or partially addressed via redaction, others were not preserved.
The parties agreed the judgment contained clerical errors (wrong statutory citation and entry date); the State agreed reformation was appropriate.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Steinmann)	Held
Admissibility of jail-call recording	Recording (as redacted) was admissible and probative of consciousness of guilt and witness-tampering	Portions about Heather’s troubles were irrelevant, hearsay, and unfairly prejudicial	Error not preserved — objections post-redaction were not specific enough; admission affirmed
Authentication of Facebook photograph	Photo was authenticated via Dr. Smith’s report and testimony; contents conveyed to jury	Photo lacked proper authentication from photographer/owner	Admission waived because Smith’s report (admitted) conveyed same information; issue overruled
Hearsay in Detective Earles’s testimony	Testimony reciting Heather’s statements explained events surrounding interviews	Statements were hearsay and should have been excluded	Objection at trial was narrative, not hearsay; appellate complaint not preserved; issue overruled
Clerical mistakes in judgment (statute & date)	State agreed judgment should be reformed to correct statute and entry date	Sought correction to reflect accurate statute (Penal Code §21.11(a)(1)) and date	Court reformed judgment to correct statute and entry date and affirmed as reformed

Whitaker v. State, 286 S.W.3d 355 (Tex. Crim. App. 2009) (objections must specifically identify inadmissible portions to preserve error)
Sonnier v. State, 913 S.W.2d 511 (Tex. Crim. App. 1995) (when exhibits contain admissible and inadmissible material, objections must pinpoint challenged parts)
Jones v. State, 843 S.W.2d 487 (Tex. Crim. App. 1992) (trial court should not be required to sift exhibits; consequences for insufficiently specific objections)
Tienda v. State, 358 S.W.3d 633 (Tex. Crim. App. 2012) (trial court’s threshold authentication decision reviewed for abuse of discretion)
Hughes v. State, 878 S.W.2d 142 (Tex. Crim. App. 1993) (authenticator need not be photographer; witness may testify photograph accurately represents scene/person)
Ford v. State, 919 S.W.2d 107 (Tex. Crim. App. 1996) (photographic objection waived if same information is conveyed to the jury in another form)
Banks v. State, 708 S.W.2d 460 (Tex. Crim. App. 1986) (appellate courts may reform judgments when record supplies necessary data)