The Georgia Court of Appeals ruled that a confidential informant involved in a drug trafficking investigation was a participant-informer, not a mere tipster, affirming the trial court’s decision to keep his identity private.

The case involved a Hall County defendant convicted of possession of cocaine with intent to distribute, criminal attempt to sell cocaine, and use of a communication facility in a felony. The defendant appealed, arguing that the State should have been required to reveal the informant’s identity due to his active involvement in the undercover operation.