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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.


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