First, the government creates numerous warrant clause exceptions. Then it figures there are so many exceptions there is no point in continuing the right to resist an illegal entry.
The VA Supreme Court or Court of Appeals did something like this some years ago. In Christian vs Commonwealth the court said there is no right to physically resist an unlawful detention.
So, you and I have no right to resist an unlawful detention in VA. But, once we're cuffed--for officer safety, of course--there is no way we could resist a false arrest if the cops decide to carry it further.