In Laporte v. State, 840 S.W.2d 412 (Tex. Crim. App. 1992), in a single trial based on separate indictments, a jury convicted LaPorte of possession of marihuana and possession of methamphetamine with intent to deliver. Id. at 413. The jury assessed punishment at confinement for twenty-five years and thirty-five years, respectively. Id. The trial court ordered that the sentence in the methamphetamine conviction be consecutive to that in the marihuana conviction. Id. The Texas Court of Criminal Appeals reversed the judgment. Id. The court reasoned the Legislature intended a single criminal action to refer to a single trial or plea proceeding. Id. at 414. Section 3.03 applies whenever a defendant is prosecuted in a single criminal action, whether pursuant to one charging instrument or several. Id. at 415. The trial court's general authority under Article 42.08 to order consecutive sentences is statutorily limited by Section 3.03. Id. "If the facts show the proceeding is a single criminal action based on charges arising out of the same criminal episode, the trial court may not order consecutive sentences." Id. at 415. Therefore, the court held the judgments should be reformed to delete the cumulation order. Id.