Ford v. State (1972)

In Ford v. State, 484 S.W.2d 727 (Tex. Crim. App. 1972), there was a supermarket robbery and a robbery-murder at a chemical company. The former was committed by four men, the latter by one. Id. at 730. The court noted the similarities were few and "neither distinguishing, novel nor unusual." Id. The court continued: "Had there been evidence that the same pistol had been used in both robberies, or that four men committed both, acting in the same manner in each instance, or had there been some distinguishing characteristic, then a different result might be reached." Id.