occurred after the arrest, not during the Terry frisk. Therefore, the contraband was obtained from a valid search incident to a valid arrest. Although the issue in the present case arises from a Terry stop, Kentucky cases involving detainees’ claims of self-defense during arrests prove instructive. It is well-settled that “[tjhere is no right to use self-defense during an arrest.” Stopher v. Commonwealth, 57 S.W.3d 787, 803 (Ky.2001) (citing Baze v. Commonwealth, 965 S.W.2d 817, 823 (Ky.1997)). In Baze, the Court affirmed the trial court’s determination that appellant’s beliefs regarding the legality of his arrest were irrelevant to any claim of justification for murdering police officers. Id. Further, the commentary to Kentucky’s resisting arrest statute explains that “th Cir.1995) (<HOLDING>). We conclude that Kavanaugh’s assault of
holding that a defendants response to even an invalid arrest or terry stop may constitute independent grounds for arrest holding that the forceable stop at issue was an investigatory stop rather than an arrest holding avoiding arrest is not the same as resisting arrest holding that an initially lawful terry stop can be converted into a fullfledged arrest for which probable cause is required but noting that there is no bright line rule for determining when an investigatory stop crosses the line and becomes an arrest holding invalid warrant did not create probable cause for arrest