Commonwealth v. Santana 2008 PA Super 246

Topic: Escape-What is a detention for escape purposes

Summary: Where law enforcement has put on a display of force and attempts to “restrain the liberty” of the defendant, there is a detention. Example: Santana was asked to come off of a roof to speak to the police. Santana jumped off the roof, stiff-armed an officer who tried to restrain him, was told to stop, and ended up getting “tased.” In this case, the Superior Court found there was a detention.

http://www.pacourts.us/OpPosting/Superior/out/s53030_08.pdf