California, United States of America
The following excerpt is from Joseph B., In re, 141 Cal.App.3d 864, 190 Cal.Rptr. 639 (Cal. App. 1983):
As stated in rule 31(d), a certificate of probable cause is not required where the appeal is based upon grounds occurring after entry of the plea and which do not challenge the validity of the plea. (See People v. Kaanehe, supra, 19 Cal.3d at p. 8, 136 Cal.Rptr. 409, 559 P.2d 1028.) Falling within this exception is the minor's first contention, that the juvenile court abused its discretion by ordering him removed from his parents' custody.
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