I have a case (2004 offense date) where the defendant showed the child victim child pornography. My judge severed out the child pornography counts under the old law.

Does anyone know of any cases dealing with the admissibility of child pornography in an aggravated sexual assault trial for purposes of proving intent/grooming of the child?

I do not know the answer but I just did an appeal on a case where the child was shown pornographic movie while he touched her. The issue does not directly answer your question, but I argued that the showing of the pornographic film, an extraneous bad act, was admissible under 38.37. See Hitt v. State 53 SW3d 697 (Notice and Rule 403 balancing test requirements) Of course we did not have any porn charges in that case as it was an adult movie. We have previously had another case where the pornographic material charge was out of a different county and the child was allowed to testify about the def showing her pornographic material. Don't know if this helps, but hope it points you in the right direction.

I tried a case in which we introduced pictures of adult and cartoon pornography from the defendant's computer because the child victim testified that the defendant would show him porn from his computer -- grooming. The case was not published, but it should be helpful: Pinson v. State, 2004 Tex. App. LEXIS 6916 (Tex. App. 2004, pet. ref'd). While the evidence was arguably legal porn, as opposed to child porn, I think you should have an easier time getting your evidence admitted under Art. 38.37. Just be careful of TRE 403 -- we only submitted samples and not all the pictures we had.

If they are showing the movie at the same time the assault is occuring, I would argue it is same transaction contextual evidence, not an extraneous bad act.

I appreciate everyone's helpful suggestions. The judge let in the picture that the defendant had shown the child as same-transaction contextual. That enabled us to get a guilty and a good sentence.

Some helpful cases that I found on the subject were Broderick v. State, 35 SW3d 67 out of Texarkana; Hawk v. State, 969 SW2d 46 out of Beaumont; Redwine v. State, 2005 WL 550660 (unpublished) out of Beaumont; and Houston v. State, 832 SW2d 180 out of Waco.