An uncorroborated first time informant provided no reasonable suspicion for defendant’s stop. State v. Donnell, 2021 Tex. App. LEXIS 7813 (Tex. App. – Tyler Sept. 22, 2021):
We have reviewed the record and find that the trial court’s findings of fact are supported by the record. See Kelly, 204 S.W.3d at 818. We disagree with the State that the CI’s information and Alexander’s individual observations provided Alexander with sufficient reasonable suspicion to stop Appellant. The CI was a first-time informant, unknown to Alexander. While the CI told Alexander that she and Appellant were co-workers, Alexander did not testify that he verified this information. Nor did Alexander testify if the CI told him where she and Appellant worked, how long they had worked together, or any other details regarding their relationship. Moreover, unlike in White where the officers corroborated the defendant’s location and future movements, the officers in this case simply took the CI at her word that she was with Appellant and Appellant was using her phone to text message her drug supplier. Alexander never observed the CI and Appellant together. Unlike the officers in White, Alexander did not follow Appellant to the location, but simply waited at the county line for her to pass by while she was, according to the CI, on her way to Onalaska. The officers did not follow Appellant to see if she did, in fact, travel to a location in Onalaska. Nor did the officers verify that Appellant was in fact with the CI on the day of Appellant’s arrest.
Simply put, the officers in this case corroborated only two things regarding the CI’s tip: [the color of his truck and the direction he was heading].