State v. Cole
In State v. Cole, 172 Ariz. 590, 838 P.2d 1351 (Ariz. App. 1992), police officers were in the process of effecting an arrest by "clutching" both arms of a suspect when he "began waving his arms and physically dragged . . . two officers approximately 25 feet." When the officers . . . grabbed the suspect's shirt, . . . it tore and he fled." 838 P.2d at 1352.
The Arizona Court of Appeals sustained the escape conviction, concluding that the appellant had "escaped from actual restraint," and that "both officers had physically restrained the appellant, if only temporarily, by clutching his arms and then his shirt." Id. at 1353.