People v. Clark

This case presents question as to whether govt. proved defendant guilty beyond reasonable doubt of crime of escape under circumstances, where: (1) terms of defendant’s bond required that she report to county jail immediately upon release from halfway house; and (2) defendant failed to report to jail after she left halfway house. Appellate Court, in reversing defendant’s conviction, found that for purpose of escape offense defendant was not “in custody” at time she failed to report to halfway house because, at said time, she was out on bond and under authority of trial court, rather than under authority of Sheriff or Dept. of Corrections.