Bobby Ray Hayden, Jr., Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that the trial court did not abuse its discretion in finding that the State satisfied Texas Rule of Evidence 404(b) by delivering witness statements to the defense, thereby affirming the trial court's judgment and reversing the Court of Appeals. The majority reasoned that such delivery can constitute reasonable notice of the State's intent to introduce extraneous offenses, especially when made promptly after a timely request. Three dissenting opinions argued that the delivery of statements does not meet the statutory requirement of notice of intent to introduce and that the majority’s approach conflicts with prior precedent.