Lee, Rashad, PD-0562-15

Confidential informant Charles Taylor arranged and recorded a buy of 0.25 oz (≈2.56 g) of crack cocaine from Rashad Lee for $225; Taylor was searched before and after the meeting and had no money before but had a baggie after.
DPS agents (Brock/Chad Brock and Greg Wilson) aided Taylor with audio/video equipment, followed at a distance, and testified about the call, observation of two men (one with a dog), and the recovered substance; agents did not identify Lee by voice and did not search the vehicle.
Trial resulted in conviction for delivery of a controlled substance; jury sentenced Lee to 40 years and a $5,000 fine; trial court also issued a withdrawal notification for inmate trust funds under Gov’t Code §501.014.
On direct appeal the Sixth Court of Appeals affirmed, finding the non‑informant evidence (call, video/stills, search results, absence of $225 on Taylor) sufficiently corroborated Taylor under Art. 38.141.
Lee sought discretionary review arguing (1) insufficiency of corroboration under Art. 38.141 and conflict with Young v. State, and (2) procedural due process violation in withdrawing inmate funds without notice/hearing; the appeals court declined jurisdiction over the civil collection claim.

Issue	Plaintiff's Argument (Lee)	Defendant's Argument (State)	Held
Sufficiency of corroboration for confidential informant testimony under Tex. Code Crim. Proc. art. 38.141	Taylor was the only witness identifying Lee; once Taylor’s testimony is removed there is no evidence connecting Lee to the offense (cites Young/Blake)	Other evidence (phone call content, agents’ observation of two men including one with a dog, video/still images showing a hand-to-hand contact and a baggie, Taylor’s recovered cocaine and absence of the $225) tends to connect Lee	Court of Appeals: corroboration sufficient; affirm conviction
Due process / withdrawal of funds from inmate trust account (Gov’t Code §501.014)	Withdrawal notification was issued without notice/hearing; violates procedural due process and prior appellate rulings	Collection under §501.014(e) is a civil collection/withdrawal notice, and appellant did not present the issue properly in the criminal appeal	Court of Appeals: lacks jurisdiction to review withdrawal-notice procedure in this criminal direct appeal; dismissed that point

Blake v. State, 971 S.W.2d 451 (Tex. Crim. App. 1998) (accomplice/informant testimony viewed with caution; corroboration rule explained)
Young v. State, 95 S.W.3d 448 (Tex. App.—Houston [1st Dist.] 2002) (reversal where informant was sole identifier and corroboration lacking)
Cantelon v. State, 85 S.W.3d 457 (Tex. App.—Austin 2002) (describes test for corroboration by eliminating informant testimony)
Malone v. State, 253 S.W.3d 253 (Tex. Crim. App. 2008) (informant corroboration analyzed like accomplice testimony)
McDuff v. State, 939 S.W.2d 607 (Tex. Crim. App. 1997) (articulating eliminate-informant test for corroboration)
Armstrong v. State, 340 S.W.3d 759 (Tex. Crim. App. 2011) (distinguishing challenges to assessment of court costs from collection procedures)
Perez v. State, 424 S.W.3d 81 (Tex. Crim. App. 2014) (limits on raising cost-collection issues on direct criminal appeal)
Harrell v. State, 286 S.W.3d 315 (Tex. 2009) (collection under §501.014(e) is civil in nature)