In Gonzalez v. State, No. 01-95-01571-CR, 1997 WL 149517 (Tex. App.--Houston 1st Dist. Mar. 20, 1997, pet. ref'd), the First Court of Appeals rejected the State's contention that the defendant had failed to meet his burden of showing a warrantless arrest by failing to ask the officer whether he executed an arrest warrant. Rather, the court of appeals held that the officer's testimony that he stopped defendant's car based entirely on information given by a wrecker driver established that the officer did not arrest the defendant pursuant to a warrant. Id. The court also pointed out that the State called the first witnesses at the suppression hearing, indicating the defendant's initial burden of proof had been met. Id.