Illinois Compiled Statutes
720 ILCS 5/7-7 (2026)
Private person's use of force in resisting arrest
✓ current as of May 2026
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(720 ILCS 5/7-7)
(from Ch. 38, par. 7-7)
Sec. 7-7.
Private person's use of force in resisting arrest.
A person is
not authorized to use force to resist an arrest which he
knows is being made either by a peace officer or by a private person
summoned and directed by a peace officer to make the arrest, even if he
believes that the arrest is unlawful and the arrest in fact is unlawful.
(Source: P.A. 86-1475.)
Notes of Decisions
Cited in 32
cases (11 in the last 5 years), 1994–2026 · leading case: Cindy Abbott v. Sangamon Cnty., 705 F.3d 706 (7th Cir. 2013).
Cindy Abbott v. Sangamon Cnty., 705 F.3d 706 (7th Cir. 2013). “3d at 484 ; see 720 ILCS 5/7-7; People v. Villarreal, 152 Ill.”
People v. McIntosh, 2020 IL App (5th) 170068 (Ill. App. Ct. 2020). “2d 459, 464 (1974); 720 ILCS 5/7-7 (West 2012). In People v. Abrams, 48 Ill.”
City of Champaign v. Torres, 824 N.E.2d 624 (Ill. 2005). “" 720 ILCS 5/7-7 (West 2002). Our court has applied section 7-7 to cases brought under section 31-1 of the Criminal Code of 1961 (720 ILCS 5/31-1 (West 2002)), the state counterpart to the municipal ordinance at issue in this case.”
People v. Williams, 640 N.E.2d 981 (Ill. App. Ct. 1994). “) The State responds that the self-defense instruction was properly rejected since there was no evidence to support it.”
Brooks v. City of Aurora, Ill., 653 F.3d 478 (7th Cir. 2011). “See also 720 ILCS 5/7-7 ("A person is not authorized to use force to resist an arrest which he knows is being made either by a peace officer or by a private person summoned and directed by a peace officer to make the arrest, even if he believes that the arrest is unlawful and…”
People v. Jones, 2015 IL App (2d) 130387 (Ill. App. Ct. 2015). “2d 234, 241-42 (2005) (citing 720 ILCS 5/7-7 (West 2002)). Where, however, the officer’s act is the entry into (or remaining within) the defendant’s home, section 7-7 does not apply.”
People v. Borders, 2020 IL App (2d) 180324 (Ill. App. Ct. 2020). “Under section 7-7 of the Criminal Code of 2012 (Code) (720 ILCS 5/7-7 (West 2018)), “[a] person is not authorized to use force to resist an arrest which he knows is being made *** by a peace officer ***, even if he believes that the arrest is unlawful and the arrest in fact is…”
Keith Gower v. Jeffrey Vercler & Ryan Garrett, 377 F.3d 661 (7th Cir. 2004). “Because we hold that Gower's arrest did not abridge any of his constitutional rights, we need not discuss whether, if his constitutional rights had been violated, Gower would have been entitled to physically resist arrest or whether 720 ILCS 5/7-7 is unconstitutional as overly…”
People v. Shipp, 2015 IL App (2d) 130587 (Ill. App. Ct. 2015). “On appeal, our supreme court held that, under section 7-7 of the Code (720 ILCS 5/7-7 (West 2008)), the exclusionary rule could not be used to suppress evidence gained as the result of a defendant’s resistance to an arrest, even if the arrest was unlawful.”
People v. Shipp, 2015 IL App (2d) 130587 (Ill. App. Ct. 2015). “On appeal, our supreme court held that, under section 7-7 of the Code (720 ILCS 5/7-7 (West 2008)), the exclusionary rule could not be used to suppress evidence gained as the result of a defendant’s resistance to an arrest, even if the arrest was unlawful.”
Gregory v. Oliver, 226 F. Supp. 2d 943 (N.D. Ill. 2002). “Here is 720 ILCS 5/7-7: A person is not authorized to use force to resist an arrest which he knows is being made either by a police officer or by a private person summoned and directed by a police officer to make an arrest, even if he believes that the arrest is unlawful and the…”
City of Champaign v. Torres, 803 N.E.2d 971 (Ill. App. Ct. 2004). “Moreover, the supreme court may simply have been noting that the reasoning in Locken would not apply to an unlawful entry situation as the court based its holding on section 7-7 of the Criminal Code (720 ILCS 5/7-7 (West 2002)), addressing a private person's use of force in…”
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