California, United States of America
The following excerpt is from People v. Gocke, C082015 (Cal. App. 2017):
"Under section 1237.5, an appeal from a conviction predicated on a [no contest] plea requires a certificate of probable cause. 'Notwithstanding the broad language of section 1237.5, it is settled that two types of issues may be raised in a guilty or nolo contendere plea appeal without issuance of a certificate: (1) search and seizure issues for which an appeal is provided under section 1538.5, subdivision (m); and (2) issues regarding proceedings held subsequent to the plea for the purpose of determining the degree of the crime and the penalty to be imposed.' [Citation.]" (People v. Richardson (2007) 156 Cal.App.4th 574, 596.)
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