In Lewis v. State, 30 S.W.3d 510, 512 (Tex. App. 2000), the Texas Court of Appeals affirmed a conviction for resisting arrest under similar facts. The Texas statute defining the crime of resisting arrest included the phrase "effecting an arrest," and Lewis argued that any resistance occurred after he was handcuffed and the arrest had been completed. Lewis, 30 S.W.3d at 511. After determining that "effecting an arrest" entailed a process or transaction, id. at 512, the court concluded that sufficient evidence supported the jury verdict of guilt: The record contains evidence that any resistance put forth by appellant occurred after he was handcuffed pursuant to the directive of another officer. Yet, according to the testifying officer, the struggle began "in quick succession" after the cuffs were placed on appellant; "it was a matter of seconds, a minute maybe, something like that." . . . Much like the Court of Criminal Appeals, we too would desire a "bright-line" test for determining when an arrest has occurred. Rhodes v. State, 945 S.W.2d 115, 118 (Tex. Crim. App. 1997). Yet, one does not exist. Id. Nor could it given the myriad of potentialities swirling in an encounter between police and those suspected of criminal activity. Thus, we turn to general rules to guide our determination on a case-by-case basis. And, in this case, we find some evidence upon which a rational jury could have held that appellant was not "successfully" restricted or restrained until after the struggle began . . . .Lewis, 30 S.W.3d at 513.