What are the consequences of a traffic stop that resulted in a defendant being found guilty of resisting arrest?

Defendant next contends his convictions for resisting arrest must be reversed because Deputy Paonessa was not acting lawfully in the initial stop. Both parties agree that under California law a defendant cannot be convicted of resisting arrest if the officer was not acting lawfully at the time of the arrest. (People v. Simons (1996) 42 Cal.App.4th 1100, 1109, 50 Cal. Rptr.2d 351.) Since we have already concluded the traffic stop was not justified and therefore unlawful, we agree the convictions for resisting arrest cannot stand.