Latisha Leann White v. State, 12-16-00111-CR

Latisha Leann White pleaded guilty pursuant to plea bargains to four offenses and received ten-year sentences, all suspended with ten years community supervision.
The State filed applications to revoke community supervision; two allegations were abandoned and White pleaded true to the remainder.
The trial court revoked supervision and sentenced White to eight years’ imprisonment in each case.
Each judgment assessed a $133 consolidated court fee and other costs; one judgment’s total cost figure ($289) differed from its bill of costs ($284).
White appealed asserting (1) the consolidated court costs were unconstitutional and (2) one judgment contained a typographical error as to total costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of $133 consolidated fee under Tex. Loc. Gov't Code §133.102	White: fee includes unconstitutional components and should be reduced/removed	State: Salinas-based reduction does not apply because White’s trial ended before Salinas mandate and no timely PDR preserved claim	Court: Overruled; Salinas relief inapplicable because proceedings ended before Salinas and no timely PDR was pending
Alleged typographical error / discrepancy between bill of costs ($284) and judgment ($289)	White: judgment contains a typo and should be modified to match bill of costs	State: record unclear whether typo; remedy is a nunc pro tunc in trial court; court should nonetheless test whether assessed costs have a record basis	Court: Overruled; $5 electronic filing fee provides a record basis for the $289 total, so no correction needed on appeal

Johnson v. State, 423 S.W.3d 385 (Tex. Crim. App. 2014) (standard for assessing and reviewing court costs in criminal cases)