A person who flees from an officer attempting to make a lawful arrest can be charged with “willful resistance.” Appellant fled police officers trying to arrest him. One of the officers fell during the pursuit, suffering injuries including fractures. Appellant was charged with two violations of Penal Code section 148.10, which applies when a person who willfully resists a police officer proximately causes the officer to suffer serious bodily injury or death as a consequence. The trial court granted appellant’s section 995 motion, which argued that the prosecutor had failed to establish “willful resistance.” The appellate court reversed the trial court’s ruling on the 995 motion. An act of flight can constitute willful resistance. The legislative history of section 148.10 supports that conclusion; the section was established precisely for this situation.