California, United States of America
The following excerpt is from People v. Shuemake, A153884 (Cal. App. 2019):
A defendant must file a certificate of probable cause to appeal from a judgment after a plea of guilty, except, as relevant here, where 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)(B); see 1237.5; People v. Cuevas (2008) 44 Cal.4th 374, 379.)
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