Hall v. Commonwealth
Court of Appeals of Virginia
1Opinion of the Court
JAMES W. HALEY, JR., Judge.
I. INTRODUCTION
Code § 18.2-478 reads in relevant part: “[I]f any person lawfully in the custody of any police officer ... escapes fi*om such custody by force or violence, he shall be guilty____” Convicted of a violation of that statute, Antoine Lanier Hall maintains that he was not in custody and that the condition of custody is a condition precedent to escape from the same. Finding a police officer effected an arrest of Hall by touching him for the purpose of arrest and that persons under arrest are always in custody, we affirm.
II. BACKGROUND
On December 20, 2007,…
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