On July 3, 1983, a police officer approached Roy Sanchez after recognizing him and discovering a misdemeanor warrant had been issued for his arrest. The officer called to Sanchez to stop and, after circling around a car in a parking lot, told him he was under arrest. Sanchez fled, but was later convicted of escape in the third degree. This verdict was overturned on appeal. The Arizona Supreme Court addressed the narrow issue of what constitutes 'constructive restraint pursuant to an on-site arrest.' It was also concerned with a potentially uneven application of the State's escape statutes. The paper discusses the court's rationales, as well as ramifications of the decision. It comments that the Sanchez ruling places the courts in the difficult position of examining the physical position of the police officer and the suspect to determine whether an arrest has occurred and the process of taking the suspect to the station commenced. The court made it clear that the Arizona Legislature is the appropriate body to criminalize fleeing from attempted arrest and expressly invited the legislature to do so. 47 footnotes.