Javier Noel Campos v. State, 01-13-00417-CR

Appellant Javier Noel Campos was convicted in one trial on three counts of aggravated sexual assault of a child and sentenced to 68 years, with sentences cumulated.
At a pretrial hearing, Campos moved to testify without impeachment by prior convictions, arguing a 1992 felony aggravated-assault conviction was inadmissible under Rule 609(b) because it was more than ten years old.
The State sought to impeach by cross-examining about the 1992 conviction, arguing it could be "tacked" to a 2006 misdemeanor assault conviction to fall within Rule 609(b)’s ten-year window.
The trial court permitted impeachment based on tacking and allowed cross-examination about the 1992 conviction.
The First Court of Appeals affirmed Campos’s convictions; Campos sought discretionary review. The Texas Court of Criminal Appeals remanded the case to the Court of Appeals for further analysis in light of controlling authority addressing tacking.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of a >10-year-old conviction under Tex. R. Evid. 609(b)	The 1992 felony is inadmissible because more than 10 years elapsed since conviction/release; the State cannot "tack" the 2006 misdemeanor to make it timely	The State may "tack" a more recent conviction (2006) onto an older conviction (1992) to bring the older conviction within Rule 609(b)’s ten-year limit	The case was remanded for reconsideration in light of Meadows; appellant argues tacking is impermissible and trial court erred (trial court previously allowed tacking)

Meadows v. State, 455 S.W.3d 166 (Tex. Crim. App. 2015) (rejects common-law "tacking" to circumvent Rule 609(b)’s ten-year limitation)
Theus v. State, 845 S.W.2d 874 (Tex. Crim. App. 1992) (trial-court discretion on admitting remote convictions; review for abuse of discretion)
Miller v. State, 196 S.W.3d 256 (Tex. App.—Fort Worth 2006) (discusses Rule 609 and standards for remote-conviction admission)