Kevin B. Sauceda, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals reversed the Court of Appeals and remanded for a harm analysis, holding that the trial court erred in allowing the State to admit the entire videotaped interview under Rule 107 when the defense sought only narrow impeachment testimony. The Court found that the error was properly preserved for review and that Rule 107 does not require admission of extraneous offense content absent a showing of necessity. Justice Johnson, in a concurring opinion, argued that the error was not preserved because the inadmissible evidence was never admitted, while Justice Keller dissented, maintaining that no error occurred. The opinion clarifies the application of the rule of optional completeness in criminal trials.