Jose Aldape v. State, 14-15-00988-CR

Appellant was convicted of robbery after abducting the complainant, claiming to be a federal agent, displaying a firearm, transporting him in a truck, and extorting $1,000 for his release. Appellant was arrested in the same truck days later.
Defense theory at trial suggested the complainant fabricated the robbery to gain leverage in a business dispute, obtain a visa, or dispose of property the complainant believed stolen. Defense impeached credibility and elicited evidence suggesting alternate explanations for events.
During rebuttal, the State introduced testimony from two Hispanic victims who described substantially similar incidents in which appellant posed as an officer, used the same truck, and extorted or robbed them shortly before the charged offense.
Trial court admitted the extraneous-offense evidence after a proffer and gave a limiting instruction to the jury, stating the evidence could only be considered for non-propensity purposes (motive, intent, plan, knowledge, etc.).
Appellant appealed, arguing under Tex. R. Evid. 403 that the probative value of the extraneous-offense evidence was substantially outweighed by unfair prejudice; the Fourteenth Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by admitting extraneous-offense evidence under Tex. R. Evid. 403	State: evidence was highly probative to rebut defense fabrication theory and showed a modus operandi, so need justified admission	Aldape: probative value was substantially outweighed by unfair prejudice and jury might decide guilt by propensity	Affirmed — admission within trial court's discretion; probative value outweighed danger of unfair prejudice

De La Paz v. State, 279 S.W.3d 336 (Tex. Crim. App. 2009) (standard of review for Rule 403 balancing)
Mechler v. State, 153 S.W.3d 435 (Tex. Crim. App. 2005) (four-factor Rule 403 analysis)
Gigliobianco v. State, 210 S.W.3d 637 (Tex. Crim. App. 2006) (definition of probative value)
Owens v. State, 827 S.W.2d 911 (Tex. Crim. App. 1992) (modus operandi exception to extraneous-offense rule)
Bass v. State, 270 S.W.3d 557 (Tex. Crim. App. 2008) (extraneous offenses admissible to rebut fabrication)
Robbins v. State, 88 S.W.3d 256 (Tex. Crim. App. 2002) (doctrine of chances and logical improbability)
Taylor v. State, 920 S.W.2d 319 (Tex. Crim. App. 1996) (comparative heinousness and jury prejudice)
Lane v. State, 933 S.W.2d 504 (Tex. Crim. App. 1996) (use of limiting instructions to minimize propensity inference)
Daggett v. State, 187 S.W.3d 444 (Tex. Crim. App. 2005) (need for a tailored limiting instruction when purpose of extraneous evidence is narrow)
Blackwell v. State, 193 S.W.3d 1 (Tex. App.—Houston [1st Dist.] 2006) (limiting instruction phrasing and "no other purpose" implication)
Montgomery v. State, 810 S.W.2d 372 (Tex. Crim. App. 1990) (probative value presumed weightier than prejudice absent contrary finding)
Beam v. State, 447 S.W.3d 401 (Tex. App.—Houston [14th Dist.] 2014) (proponent's need is strong where issue is hotly contested)