Escaping Arrest After Police Officer Discovered Drugs Case

In Medford v. State, 13 S.W.3d 769, (Tex. Crim. App. 2000), a police officer approached the defendant, who matched the description of the suspect in an arrest warrant, to conduct an investigatory detention. See Medford, 13 S.W.3d at 770-771. During a search of Medford's pants pocket, the officer discovered a matchbox containing a substance that appeared to be "crack" cocaine. See id. The officer told Medford that he was under arrest. As the officer attempted to place Medford in handcuffs, Medford broke free of the officer's grip and fled. He was captured, indicted, and found guilty of possession of cocaine and escape. Noting that the word arrest is a "technical term possessing a long, established history in the common law," Medford, 13 S.W.3d at 772, the court concluded that, for purposes of the escape statute, "the obvious conclusion we draw is that neither jurors nor reviewing courts can rely solely on Article 15.22's definition of arrest," but that it could provide guidance to the meaning of the word in other contexts. Medford, 13 S.W.3d at 772. Focusing on the "fact finder's application of the reasonable person standard," the court found an arrest complete "when a person's liberty of movement is successfully restricted or restrained, whether this is achieved by an officer's physical force or the suspect's submission to the officer's authority," and further, only if "a reasonable person in the suspect's position would have understood the situation to constitute a restraint on freedom of movement of the degree which the law associates with formal arrest." Medford, 13 S.W.3d at 773, (citing United States v. Corral-Franco, 848 F.2d 536, 540 (5th Cir. 1988)).