The AP did an article that is a must read for persons dealing with domestic violence issues within the criminal justice system.
Here is a segment of it:
As text messaging has boomed in recent years, it has also given rise to so-called "textual harassment." Text messages antagonize recipients in a way that is not easily ignored: Most people are never far from their cell phones, and the gadgets tend to blink and chirp until unopened messages are acknowledged. Adding another sting, the victims are often charged by their cell phone companies for receiving the messages.
The report found 23 percent of stalking or harassment victims reported in 2006 that the stalker had used some form of cyberstalking.