In Medford v. State, 990 S.W.2d 799 (Tex. App.--Austin 1999), vacated and remanded, 13 S.W.3d 769 (Tex. Crim. App. 2000), a police officer, believing that Medford matched the description of a person for whom an arrest warrant had been issued, approached Medford and asked him to identify himself. Because it was after dark and in a dangerous part of town, the officer frisked Medford for weapons and discovered a matchbox containing crack cocaine. Id. The officer told Medford he was under arrest and instructed him to place his hands behind his back. Id. The officer touched Medford's left arm with his hand and was about to handcuff him when Medford lunged free and began to run. Id. Refusing to equate "custody" with "seizure" under the Fourth Amendment, we held that Medford was not in custody when he fled from the officer, reversed his conviction for escape, and rendered a judgment of acquittal. Id. at 810-11. The Court observed that Medford "apparently committed the offense of evading arrest." Id. at 811. After granting the State's petition for discretionary review, the court of criminal appeals wrote an opinion that was largely consistent with ours. Medford v. State, 13 S.W.3d 769 (Tex. Crim. App. 2000). The court wrote: "An arrest of a person carries with it an element of detention, custody or control of the accused. The mere fact that an officer makes the statement to an accused that he is under arrest does not complete the arrest. There must be custody or detention and submission to such arrest." Id. at 772-73. An arrest must be complete in order to distinguish the offense of escape from the offense of evading arrest. Id. at 773. "For purposes of the escape statute, an "arrest" is 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. Furthermore, an arrest is complete 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." . . . It is necessary . . . to focus the fact finder's application of the reasonable person standard into the context of an arrest to prevent a conviction based upon some less intrusive type of seizure." Id. On remand, the Court concluded that the officer's stop-and-frisk of Medford constituted a detention, but not a completed arrest, and that a reasonable person would not have understood himself to be restrained to the degree the law associates with a formal arrest. Medford v. State, 21 S.W.3d 668, 670 (Tex. App.--Austin 2000, no pet.). The officer's announcement that Medford was under arrest did not in itself complete the arrest. Id. The officer was unable to complete the arrest by successfully restricting or restraining Medford's liberty of movement before Medford fled. Id. The Court again reversed Medford's conviction for escape and rendered an acquittal. Id. In sum, in Medford v. State, the officer had informed the appellant that he was under arrest and instructed him to place his hands behind his back. The officer also testified that he touched the defendant's left arm and was about to handcuff him when the defendant lunged free and began running. Medford 1, 990 S.W.2d at 802. In holding that evidence was not sufficient to show Medford was in "custody" at the time he fled, the court applied the definition of arrest contained in article 15.22 of the Code of Criminal Procedure which states that a person is arrested when he has actually been placed under restraint or taken into custody. See Tex. Code Crim. Proc. Ann. art. 15.22 (Vernon 1977). Medford 1, 990 S.W.2d at 806. Having done so, the court concluded that under that definition, the arrest had not been completed before Medford's flight and, therefore, he could not be guilty of the crime of escape. Medford 1, 990 S.W.2d at 811.