Burke v. State (2011)
In Burke v. State, 371 S.W.3d 252, 257 (Tex. App.--Houston 1st Dist. 2011, pet. ref'd, untimely filed), a child-complainant testified that the defendant had assaulted him on several occasions before the assault for which the defendant was on trial. 371 S.W.3d at 255.
There, the complainant's account of the offense included more violent details than his accounts of earlier assaults. Id. at 258.
Therefore, the Court held that the brief accounts of earlier sexual assaults were not more inflammatory than the more detailed and shocking account of the charged offense. Id. at 258.
Accordingly, they presented little danger of unfair prejudice. Id.