Artis Ladelle Williams v. State, 06-15-00154-CR

Appellant Artis Ladell Williams pleaded guilty to two counts: possession of methamphetamine (third-degree felony) and possession of cocaine (second-degree felony).
After plea, a jury assessed punishment: 10 years for methamphetamine and 15 years for cocaine; probation was denied.
During punishment deliberations the jury asked whether sentences would run concurrently or consecutively; the judge referred the jury back to the charge rather than directly answering.
The jury charge contained a modified/combined parole-law instruction; defense contends the modification was improper and confusing.
The judgment also assessed $4,211.25 in court-appointed attorney fees against Williams, who remained indigent and was represented by appointed counsel throughout.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by submitting a modified parole-law instruction and by its response to the jury note about concurrency	The modified parole instruction confused the jury and permitted speculation about parole’s effect on total incarceration, leading to harm in punishment determination	No contemporaneous objection to the charge or response was made at trial; jury was properly referred to the written charge	Appellant requests reversal and remand for a new punishment trial due to erroneous parole-law submission and prejudicial effect (as argued in brief)
Whether the trial court erred in ordering reimbursement of court-appointed attorney fees against an indigent defendant	Williams argues Art. 26.05(g) requires a present determination of ability to pay and no evidence supports assessing fees against him	State likely argues fees may be assessed if court determines defendant has resources to reimburse (not developed in brief)	Appellant asks that the judgment be modified to delete assessment of appointed counsel fees (as argued in brief)

Almaza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1984) (standard on harm from charge error)
Skinner v. State, 956 S.W.2d 532 (Tex. Crim. App. 1997) (egregious-harm standard for unpreserved jury-charge error)
Armstrong v. State, 340 S.W.3d 759 (Tex. Crim. App. 2011) (requirements for assessing attorney-fee reimbursement)
Mayer v. State, 309 S.W.3d 552 (Tex. Crim. App. 2010) (present ability-to-pay is required before ordering reimbursement)
Cates v. State, 402 S.W.3d 250 (Tex. Crim. App. 2013) (ability-to-pay analysis applies at the time of fee assessment)
Loun v. State, 273 S.W.3d 406 (Tex. App. — Texarkana 2008) (discussing parole instruction error)
Rogers v. State, 38 S.W.3d 725 (Tex. App. — Texarkana 2001) (parole-instruction modification can be erroneous)
Villareal v. State, 205 S.W.3d 103 (Tex. App. — Texarkana 2006) (parole-charge and jury-note issues)