Finally, self-defense has been recognized by other jurisdictions in obstruction prosecutions. People v. Willey, 85 Ill.App.3d 734, 41 Ill.Dec. 621, 407 N.E.2d 1119, 1120 (1980); State v. Yeutter, 252 Neb. 857, 566 N.W.2d 387, 391 (1997); Yetter v. State, 987 P.2d 666, 669-70 (Wyo. 1999). Consequently, we conclude self-defense is an available defense against the charge of obstructing a peace officer when a defendant reasonably believes that unreasonable or excessive force is being used by the peace officer.
Tried together with defendant was his brother, codefendant Steven Willey, whose appeal has been addressed in a separate opinion. ( People v. Willey (1980), 85 Ill. App.3d 734.) The facts pertinent to Steven's appeal are also relevant to this appeal.