Quick note: Oklahoma Appellate Court: No reasonable expectation of privacy in text messages sent to another person's phone

The case is State v. Marcum, No. S-2012-976 (OK App. Ct. Jan. 28, 2014). FourthAmendment.com's summary of the case (with slight modifications):

A search warrant was used to obtain [cell phone text records]. [The court held] that [t]here is no reasonable expectation of privacy in the records of another person’s account <even if those records pertain to you>. When you hit “send” and [transmit a] text message to another person, you’ve lost any reasonable expectation of privacy in the message.

The court's holding can be boiled down to the following paragraph:

Addressing only the narrow question before us, Marcum has not demonstrated a reasonable expectation of privacy in the records seized from U.S. Cellular for Miller's phone account. This Court adopts the reasoning of the courts which have concluded that there is no expectation of privacy in the text messages or account records of another person, where the defendant has no possessory interest in the cell phone in question, and particularly where, as here, the actual warrant is directed to a third party. 

The court frames it as a novel issue, but I think the third-party doctrine compels a rather straightforward outcome.