He can pick his options.
He can sue in civil court (Small Claims) and get a judgment against the person. But, he needs to consider the chances of getting payment from the judgment before going through any expense of court (about $100, which he will be returned in the judgment award).
Or he can consider filing criminal charges against her. Send her a certified RRR letter detailing the work done and the bounced check. Demand that she make good on the payment within 10 days from receipt. Add that if she fails to make good, then he will consider filing fraud and theft charges against her.
Or, he can file a contractor's lien against her property.
Here are some relevant statutes:
In Texas, assuming it wasn't a post dated check, putting a 'stop pay' on a payment for goods or merchandise CAN be considered "Presumption for Theft by Check"" (Texas Penal Code, §31.06). Here is an excerpt from the Statute:
"(f) If the actor obtained property by issuing or passing a check or similar sight order for the payment of money, the actor's intent to deprive the owner of the property under Section 31.03 (Theft) is presumed, except in the case of a postdated check or order, if:
(1) the actor ordered the bank or other drawee to stop payment on the check or order;
(2) the bank or drawee refused payment to the holder on presentation of the check or order within 30 days after issue;
(3) the owner gave the actor notice of the refusal of payment and made a demand to the actor for payment or return of the property; and
(4) the actor failed to:
(A) pay the holder within 10 days after receiving the demand for payment; or
(B) return the property to the owner within 10 days after receiving the demand for return of the property."
Source:
http://www.capitol.state.tx.us/statutes/pe/pe003100.html#pe004.31.04
Further, depending on the full circumstances, this could be considered 'False Statement to Obtain Property or Credit' (Texas Penal Code, §32.32), which says in part:
"(b) A person commits an offense if he intentionally or knowingly makes a materially false or misleading written statement to obtain property or credit for himself or another."
Source:
http://www.capitol.state.tx.us/statutes/pe/pe003200.html#pe009.32.32
The full Texas statute regarding liens is in teh TX Prop Code, Chapter 53 (online copy at:
http://www.capitol.state.tx.us/statutes/py/py005300toc.html
The specific relevant sections are:
§ 53.021. Persons Entitled to Lien
§ 53.022. Property to Which Lien Extends
§ 53.023. Payment Secured by Lien
Finally, here are some links related to the issue of contractor liens in Texas:
http://www.davis-opper.com/do_main/memos/970714-002.htm
http://www.sierraphoenix.com/news/texas_mechanics_lien_changes.htm