Burnett v. State
In Burnett v. State, 88 S.W.3d 633 (Tex. Crim. App. 2002), the Court held that a Rule 44.2(b) harm analysis was the proper standard of review when an appellant claims only a violation of Code of Criminal Procedure 26.13.
Burnett, however, is not controlling here because the appellant in Burnett claimed only a violation of the Texas Code of Criminal Procedure; he did not make a federal due process claim.
The Court specifically left unresolved the question of whether a trial court's failure to admonish a defendant of the range of punishment violates his federal due process rights. Burnett at 641.