Can Court Compel to Reveal Informant's Identity ?
An informant's identity should be revealed when the testimony of the informant is necessary to a fair determination of the issues of guilt or innocence of the accused. See TEX. R. EVID. 508(c)(2); see also Bodin v. State, 807 S.W.2d 313, 317-18 (Tex. Crim. App.1991).
Before revealing the informant's identity, the informer's potential testimony must significantly aid appellant, and mere conjecture or supposition about possible relevance is insufficient.
Appellant has the burden of demonstrating that the informant's identity must be disclosed. See Abdel-Sater v. State, 852 S.W.2d 671, 673-74(Tex. App.--Houston [14th Dist.] 1993, pet. ref'd).
Appellant must make a plausible showing of how the informer's information may be important. See id.
This court must consider all of the circumstances of the case to determine if the trial court erred by not requiring the State to disclose the informer's identity. See Edwards v. State, 813 S.W.2d 572, 580 (Tex. App.--Dallas 1991, pet. ref'd).