Overcome Resistance. Any peace officer who has reasonable cause to believe that a person to be arrested has committed an offense may use reasonable force to effect the arrest, to prevent escape or to overcome resistance. A peace officer who makes or attempts to make an arrest need not retreat or desist from his efforts by reason of the resistance or the threatened resistance of the person being arrested; nor shall such officer be deemed an aggressor or lose his right of self-defense by the use of reasonable force to effect the arrest or to prevent escape or to overcome resistance. NOTE: Section 20.45 is based on § 835a of the California Penal Code. See generally B. Witkin, California Criminal Procedure Proceedings Before Trial § 110 (1963). See also 32 Cal. S. Bar J. 607(1957). It supersedes former § 843 and applies whether or not the arrest is being made pursuant to a warrant. (Obviously a warrant itself provides the officer reasonable cause to believe that the person to be arrested has committed an offense. If he has no warrant, the officer may rely on his own observations.) The section does limit the officer to use the "reasonable force." Compare former § 843 ("all necessary means"). See also 9 GCA § 7.86 (justification as a defense; no right to resist arrest);7.92 (justification as a defense; use
of force in law enforcement). It might be noted that resisting arrest is made a misdemeanor by § 55.35 of the Criminal and Correctional Code.