Robles v. State

In Robles v. State, 85 S.W.3d 211 (Tex. Crim. App. 2002), there were only two prior convictions at issue. The defendant offered to stipulate to the two prior convictions and requested that the trial court prevent the State from introducing evidence of those convictions. The trial court denied the request and the defendant pled guilty in lieu of going to trial. In conducting a Rule 403 analysis, the Court found that the offer to stipulate diminished the probative value of judgments reflecting the prior convictions "because the same information would have been admitted in an alternate form." The Court found the risk of unfair prejudice to be high "because the judgments contained information that was not relevant in the guilt-innocence phase of trial." This extraneous information consisted of "a notation that it was a DWI-third offense [and] . . . the sentences imposed." From this information the jury could have determined that the offense charged was the defendant's "fifth alcohol-related offense" and that the defendant "had not served his full term for the last prior conviction." Under those circumstances, we found that the judgments of the prior convictions were inadmissible.