if we call it after, we might receive a "fresh" transaction from
`broadcast_tx_sync` before old transactions (which were not
committed).
Refs #1091
```
Commit is called with a lock on the mempool, meaning no calls to CheckTx
can start. However, since CheckTx is called async in the mempool
connection, some CheckTx might have already "sailed", when the lock is
released in the mempool and Commit proceeds.
Then, that spurious CheckTx has not yet "begun" in the ABCI app (stuck
in transport?). Instead, ABCI app manages to start to process the
Commit. Next, the spurious, "sailed" CheckTx happens in the wrong place.
```
Anton Kaliaev
Ethan Buchman
Zach Ramsay