In Burkes v. State, 830 S.W.2d 922 (Tex. Crim. App. 1991), several police officers responded to a report of drug dealing in an area notorious for that activity. Anticipating flight upon the arrival of the police, two officers positioned themselves in a dark field behind a nightclub. See id. As expected, the arrival of squad cars led to an exodus from the nightclub. One of the officers in the field encountered Burkes, shined a flashlight in his eyes, and ordered him to lie down on the ground. See id. The suspect was immediately handcuffed and frisked. See id. The officer, who said he considered the suspect to be under arrest, did not ask him why he was running across the field. See id. at 925. The court held that the suspect was under arrest at the time of the search. See id.