With no explanation, chose the best option from "A", "B", "C" or "D". meaning and may be interpreted according to its common usage. See Denton, 911 S.W.2d at 389 (approving of lower court’s reliance on the “plain meaning” of the statutorily undefined term in assessing the sufficiency of the evidence); Capps v. State, 171 Tex.Crim. 579, 352 S.W.2d 833, 835 (1962) (explaining that the statutory language, including the term “operate,” consists of “ordinary English words which are commonly and ordinarily understood by people generally, hence the court was not required to define them.”). Therefore, nothing in our case law suggests that a risk exists that jurors may arbitrarily apply an inaccurate definition to the term “operate” or that an express definition is required to assure a fair understanding of the evidence. Compare Medford, 13 S.W.3d at 772 (<HOLDING>). The court of appeals correctly noted that

A: holding that  arrest is a technical term possessing a long established history in the common law and it would be inappropriate if jurors arbitrarily applied their personal definitions of arrest
B: holding a defendants response to even an invalid arrest  may constitute independent grounds for arrest
C: holding that a lawful custodial arrest is a prerequisite to a search since the arrest is the authority of law justifying the search
D: holding avoiding arrest is not the same as resisting arrest
A.