I believe that there is a CCA case out there about OCA in which the Court held that multiple offenses in the same day (I think it was Burglary of Motor Vehicle) did not constitute OCA since there was not sufficient evidence to prove the underlying scheme.

Does anyone know that case and cite? Thanks.

Are you thinking of Nguyen, 1 S.W.3d 694? That is the case where the CCA said that 5 guys getting together to beat up someone isn't engaging. Rather, it requires an agreement to "work together in a continuing course of criminal activities."

The Lizard Man is innocent!