Can a defendant appeal from a judgment of conviction following a no contest plea?

Under section 1237.5, a defendant cannot appeal from a judgment of conviction following a no contest plea, unless she files with the trial court a statement "showing reasonable constitutional, jurisdictional, or other grounds going to the legality of the proceedings," and the trial court executes and files "a certificate of probable cause for such appeal with the clerk of the court." ( 1237.5, subds. (a), (b).) " 'The purpose of section 1237.5 is . . . "to discourage and weed out frivolous or vexatious appeals challenging convictions following guilty and nolo contendere pleas," ' " and the " 'requirements of section 1237.5 . . . must be strictly applied.' " (People v. Mashburn (2013) 222 Cal.App.4th 937, 941 (Mashburn).)

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There is an exception to the certificate requirement when the appeal is based on "[g]rounds that arose after entry of the plea and do not affect the plea's validity." (Cal. Rules of Court, rule 8.304(b)(4).) " 'In determining whether section 1237.5 applies to a challenge of a sentence imposed after a plea of . . . no contest, courts must look to the substance of the appeal: "the crucial issue is what the defendant is challenging, not the time or manner in which the challenge is made." ' " (People v. Buttram (2003) 30 Cal.4th 773, 781.)