See Sims, 374 Ill.App.3d at 435 (stating a self-defense instruction should have been given in a battery and resisting arrest case when the defendant, who never admitted kicking the officers, acknowledged he was "feisty" and struggled with the officers after they put him face down and began hurting him). However, there is also support to the contrary. See e.g., People v. Freneey, 2016 IL App (1st) 140328, ¶ 32; People v. Diaz, 101 Ill.App.3d 903, 914 (1981); People v. Barwicki, 2023 IL App (2d) 230142-U, ¶¶ 25-26. In any event, because we conclude defendant cannot invoke the excessive force exception, we need not decide that issue.