Can a defendant appeal the validity of his guilty plea by obtaining a certificate of probable cause from the trial court?

No appeal lies to challenge the validity of a guilty plea unless a defendant has complied with Penal Code section 1237.5 by obtaining a certificate of probable cause from the trial court. (People v. Mendez (1999) 19 Cal.4th 1084, 1088.) A defendant may, however, obtain review on appeal of so-called "noncertificate" issues¹ if the notice of appeal states such grounds. (Ibid.) Here, defendant does not challenge the validity of his plea. Instead, his notice of appeal indicates that his appeal

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