DeJarnette v. State
In DeJarnette v. State, 732 S.W.2d 346 (Tex. Crim. App. 1987), a bystander observed two men apparently rob another man on the street, throw him down, kick him, stab him, and then walk away. See 732 S.W.2d at 348.
The eyewitness described the assailant to police officers. See id. Officers began asking people in the area if they had observed anyone matching the assailant's description. See id.
One person stated that he had seen someone matching that description at a bar a few blocks away. See id.
Fifteen minutes after the crime was committed, the officers proceeded to the area around the bar, observed appellant walking away from the scene on a public street, and arrested him. See id.
The court held this arrest valid under Texas Code of Criminal Procedure Article 14.04, since the totality of the circumstances supported the arresting officer's belief that appellant was attempting to escape. See DeJarnette, 732 S.W.2d at 353.