Baker v. State (2003)
In Baker v. State, 107 S.W.3d 671 (Tex. App.--San Antonio 2003, no pet.) the San Antonio Court of Appeals held that the offenses of aggravated sexual assault, sexual assault occurring ten months later, and burglary of a habitation with intent to commit sexual assault occurring a month after the second offense were all part of the same criminal episode.
The court reasoned that the offenses were a continuing course of sexual assault on women living in the same area because each offense was directed at a woman living in or near that area, occurred in or near each woman's home while she was alone, and took place in the early morning hours; alternatively, the court reasoned that all three offenses were similar offenses under section 3.01. Id.