State v. Solis
In State v. Solis, 38 Wn. App. 484, 685 P.2d 672, 673 (Wash. App. 1984) after conviction and sentence for a felony, the defendant was paroled.
Concluding Solis had violated his parole, his parole officer issued an order and warrant for his arrest. Id. A police officer located Solis, informed him of the warrant, and grabbed his arm, but Solis "broke loose and ran away." Id.
Solis argued "he was not being detained pursuant to his conviction of a felony, as required by the escape statute; rather, he was detained for possible parole revocation." Id.
The court stated:
"The issuance of the order and warrant by the parole officer immediately and effectively suspended Mr. Solis' parole. The suspension of his parole effectively reinstated his prior felony conviction and upon arrest he would have been held pursuant to the conviction pending an on-site hearing. Until his arrest . . . he was an escapee until apprehended." Id.
Therefore, the court concluded Solis' argument--distinguishing detention pursuant to conviction from detention pursuant to possible parole revocation--failed. Id.