People v. Garza

Defendant was convicted, after bench trial, of escape. Officers, who were responding to a complaint of barking dogs (and who learned of outstanding warrant for Defendant's arrest for an unrelated felony offense while en route), were allowed in to Defendant's residence by his girlfriend. Officer saw Defendant inside and told him that he was under arrest, then escorted him downstairs and held on to his arm. Defendant then went outside and ran away, but officer caught him. Defendant was in "lawful custody" within the meaning of the escape statute. (STEIGMANN and KNECHT, concurring.)