In Getts v. State, 155 S.W.3d 153 (Tex. Crim. App. 2005), the Texas Court of Criminal Appeals addressed the time limitations between enhancements for DWI cases. Getts, 155 S.W.3d 153. Getts had three DWIs: the charged offense was 2002, and the enhancements were from 1997 and 1984. The court held that, based on the 2001 amendments to the DWI statutes, these enhancements could not elevate Getts' 2002 DWI to a third-degree felony. The 1984 conviction was too remote and there was no intervening alcohol-related conviction within ten years of the 1984 conviction. The court reasoned that all three conditions of TEX. PEN. CODE ANN. 49.09(e) were met, making the 1984 conviction unavailable for enhancement purposes: (1) the 1984 conviction was a final conviction, (2) the 2002 offense was committed more than ten years after April 29, 1984 the date of the 1984 conviction, and 3) Getts was not convicted of another alcohol-related offense within ten years of April 29, 1984. Getts, 155 S.W.3d at 156-57. The Texas Court of Criminal Appeals explained the application of the ten-year rule in former section 49.09(e). (Getts, 155 S.W.3d at 156-57.) In order to exclude a prior conviction from use for enhancement, the three conditions of section 49.09(e) must be met: (1) the prior conviction must be final; (2) the current offense must have been committed more than ten years after the latest date determined under subdivision 49.09(e)(2); (3) the defendant must not have been convicted of any other intoxication-related offense within ten years of the latest date under subdivision (2). The latest date under subdivision (2) is the later of the date of judgment of the prior conviction, the date of discharge from community supervision, the date of completion of parole, or the date the defendant completed serving a term of confinement or imprisonment for the prior conviction. (Id. at 156.)