A person may not use force to resist arrest by a known police officer, even if the arrest is unlawful. 720 ILCS 5/7-7 (West 2000); People v. Williams, 267 Ill. App. 3d 82, 640 N.E.2d 981 (1994). An exception to this rule is made when the officer uses excessive force.

¶ 14 Generally, employment records are subject to subpoena if there is a showing that the records are relevant. People v. Williams, 267 Ill.App.3d 82, 87–88, 203 Ill.Dec. 831, 640 N.E.2d 981 (1994); People v. Freeman, 162 Ill.App.3d 1080, 1098, 114 Ill.Dec. 285, 516 N.E.2d 440 (1987). “The trial court has broad discretion in ruling on issues of relevance and materiality and its determination will not be disturbed absent an abuse of discretion.”

¶ 27 The parties properly direct this court's attention to two cases in support of their arguments. The State seeks legal refuge in People v. Williams, 267 Ill.App.3d 82, 203 Ill.Dec. 831, 640 N.E.2d 981 (1994), in which a defendant was involved in a traffic stop that culminated in her being charged with battery and resisting arrest. At trial, the defendant wished to present evidence of one of the officers training and disciplinary record.

Wicks, 355 Ill.App.3d at 763; 720 ILCS 5/7-7 (West 2014). An exception to this rule is made when the officer uses excessive force. Haynes, 408 Ill.App.3d at 690; Wicks, 355 Ill.App.3d at 763; People v. Williams, 267 Ill.App.3d 82, 88 (1994). Use of excessive force by a police officer invokes the arrestee's right of self-defense.

[T]he issuance of a pretrial subpoena requires, among other things, that the documents sought be evidentiary and relevant." People v. Williams, 267 Ill. App. 3d 82, 87 (1994). " 'Relevant evidence' means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence.

¶ 42 "Generally, employment records are subject to subpoena if there is a showing that the records are relevant." People v. Collins, 2013 IL App (2d) 110915, ¶ 14 (citing People v. Williams, 267 Ill. App. 3d 82, 87-88 (1994); People v. Freeman, 162 Ill. App. 3d 1080, 1098 (1987)). "An in camera inspection of documents is required if the State refuses disclosure when defendant has made a specific demand for the document and has made a preliminary showing of the document's relevancy to a witness's trial testimony."

However, an exception applies where the officer uses an excessive amount of force during the arrest; such excessive force invokes the arrestee's right to defend herself. People v. Williams, 267 Ill. App. 3d 82, 88 (1994); 720 ILCS 5/7-1(a) (West 2012). Thus, a defendant is entitled to a self-defense instruction only where there is some evidence presented of excessive force on the part of the arresting officer.

An instruction on self-defense is required in a resisting arrest case when the defendant has presented some evidence of excessive force on the part of the arresting officer. Sims, 374 Ill. App. 3d at 432 (citing People v. Williams, 267 Ill. App. 3d 82, 88 (1994)). "Where there is some evidence in the record which, if found credible by the jury, would support a claim in the nature of self-defense or defense of another, the trial court may not weigh the evidence in deciding whether an issue has been raised entitling defendant to the instruction."

This rule is qualified, however, in that it does not apply to a situation in which an officer uses excessive force. People v. Williams, 267 Ill. App. 3d 82, 88, 640 N.E.2d 981, 985-86 (1994). The use of excessive force invokes the right of self-defense. 720 ILCS 5/7-1(a) (West 2004).

The appellate court is not a depository into which a party may dump the burden of research. People v. Williams, 267 Ill. App. 3d 82, 86 (1994). It is well settled that we are entitled to a well-reasoned argument, along with authority for such argument.