In Bowley v. State, 310 S.W.3d 431, 434 (Tex. Crim. App. 2010), Bowley testified in his own defense that he pleaded guilty to two prior offenses "because he was guilty" but that he was not pleading guilty in the present case because he was not guilty. 310 S.W.3d at 433. The State then asked if he had decided to plead not guilty because he and the State could not agree on a plea bargain. Id. The court of criminal appeals held that the State's question was proper because Bowley had opened the door to it "by creating a circumstance in which the jury could infer that his not guilty plea was truthful." Id. at 435.