What is the test for determining whether a police officer has used excessive force to make an arrest?

Absent a lawful detention, a person "may decline to listen to [an officer's] questions at all and may go on his way. [Citations.] He may not be detained even momentarily without reasonable, objective grounds for doing so; and his refusal to listen or answer does not, without more, furnish those grounds." (People v. Hughes (2002) 27 Cal.4th 287, 328, italics added.) Furthermore, when excessive force is used in making what otherwise is a lawful arrest, the arrest becomes unlawful. (People v. White, supra, 101 Cal.App.3d at pp. 164, 167.) " 'When a peace officer or a private citizen employs reasonable force to make an arrest, the arrestee is obliged not to resist, and has no right of self defense against such force. [Citations.] On the other hand, the use of unreasonable or excessive force to make an arrest constitutes a public offense. [Citation.] And all persons have a right to prevent injury to themselves by resisting a public offense (. . . 692)." (People v. Adams (2009) 176 Cal.App.4th 946, 952.) It is a question of fact whether a police officer has used reasonable force. We only determine if sufficient evidence supports the trier of fact's finding, without reweighing the evidence. (People v. Delahoussaye (1989) 213 Cal.App.3d 1, 8.)

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