Christopher v. State
In Christopher v. State, 833 S.W.2d 526 (Tex.Crim.App. 1992), the Court of Criminal Appeals held evidence that appellant was driving a stolen car when he was arrested was not admissible. Id. at 529.
In that case, the trial court admitted evidence of the extraneous offense because it established the officers' probable cause to stop and arrest the appellant. See id.
The Court of Criminal Appeals noted that ". . . the State is entitled to put on evidence of what occurred immediately before and after the commission of an offense, if that evidence is relevant to something at issue in the case, and is not inherently prejudicial." Id.
The Court explained that, while evidence that the car was stolen was relevant to the determination of probable cause, because probable cause was not contested in the case, this extraneous offense evidence was not relevant to an issue in the case. See id.
Therefore, the Court held that the trial court's admission of this evidence was error. See id.