A juvenile was convicted of delinquent conduct by escaping from police custody while under arrest for the assault of a public servant. He appealed the conviction to the court of appeals.

At trial, the evidence showed that a teacher called an assistant principal to her classroom because one of her students (the defendant) had fallen asleep in class and would not wake up. The assistant principal roused the student and brought him to her office. She called the school nurse to determine whether he needed medical treatment. While they were waiting for the nurse, the student said he did not want to wait and left. Another assistant principal intercepted him and brought the student to the nurse’s office, where the nurse determined the student was under the influence of drugs.

The school district police were contacted. The student became angry, stood up and forced his way out of the nurse's office. The school district police arrived and attempted to restrain the student. The student struggled and head-butted one of the assistant principals in the face. One of the officers placed the student’s hands behind his back, handcuffed him and escorted the student to the principal’s office. The officer testified that he informed the student that he was being charged with assault on a public servant and was being arrested. The officer’s partner arrived and the officers prepared to escort the student to a police car. The student broke away from the officers and, still in handcuffs, ran through the school cafeteria, out the exit door and into the school parking lot. The officers pursued and eventually captured the student.

The student disputed the officer’s testimony and claimed he was never told that he was under arrest. He claimed that he did not know he was under arrest when he ran from the officers while wearing handcuffs.

A person commits the offense of escape if the person escapes from custody while under arrest, lawfully detained, charged, or convicted of an offense. It is not necessary for a person to be told that they are under arrest in order to be convicted of this offense, but the circumstances must be such that a reasonable person would have understood that their freedom of movement was being restrained to a degree that is associated with being under arrest.

The court of appeals upheld the student's conviction, ruling that, even if they accepted the student’s version of events and found that he was not told that he was under arrest, a reasonable person would have understood that he was under arrest in light of the circumstances present at the time he attempted to escape.