Alford v. State
The Court, in Alford v. State, 866 S.W.2d 619 (Tex. Crim. App. 1993), made it plain that 6.01(a)'s requirement of voluntary conduct has nothing to do with threats, coercion, or free will, but rather refers only to one's physical bodily movements.
It insists that "issues concerning coercion or appellant's free will are extraneous to the 6.01(a) inquiry" and that it does not matter that he was transported into the jail against his will because he was under arrest.
In Alford, the Court rejected a broad definition of voluntary that would incorporate a concept of free will.
Instead, we concluded that a narrower construction of voluntarily as utilized in 6.01(a) was appropriate. Alford, 866 S.W.2d at 624.
Specifically, we held that voluntarily "means the absence of an accidental act, omission or possession," and that voluntariness "refers only to one's physical bodily movements." Id.