The Pennsylvania Supreme Court held that resistance to an arrest found to be unlawful cannot result in a conviction for resisting arrest but can result in a conviction for aggravated assault.
Commonwealth v. Biagini, 655 A.2d 492 (Pa. 1995).
Alexandra W. Tauson,
Criminal Law - Resisting Arrest - Unlawful Arrest,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol34/iss3/12