California, United States of America
The following excerpt is from People v. Haigler, E051052, Super.Ct.No. FSB901818 (Cal. App. 2011):
1. Defendant points out that the trial court also found the text messages admissible to prove that defendant owned or had control over the cell phone. He points out that ownership of the phone was not in dispute and that the messages had no tendency to prove ownership in any event. We review the court's ruling, however, not its rationale, and affirm the judgment if the ruling was correct on any basis. (People v. Zapien (1993) 4 Cal.4th 929, 976.)
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