In Parrish v. State, 869 S.W.2d 352, 354 (Tex. Crim. App. 1994), the Texas Court of Criminal Appeals reevaluated what is meant by "same elements" after the Dixon opinion: We likewise think it reasonably clear from the various opinions in Dixon that the essential elements relevant to a jeopardy inquiry are those of the charging instrument, not of the penal statute itself. Statutory elements will, of course, always make up a part of the accusatory pleading, but additional non-statutory allegations are necessary in every case to specify the unique offense with which the defendant is charged. Parrish, 869 S.W.2d at 354.