Does a defendant have to obtain a certificate of probable cause to challenge his sentence under section 654 of the California Criminal Code?

We may review this contention even though defendant did not obtain a certificate of probable cause. Defendant's plea agreement did not specify a lid sentence, i.e., a sentence less than the maximum he could receive if sentenced on all the charges and enhancements. Instead, the trial court informed defendant that his plea did not prevent the trial court from imposing the maximum sentence. Because defendant's sentence was not negotiated, he did not waive or forfeit his claim under section 654. (See, e.g., People v. Shelton (2006) 37 Cal.4th 759, 769 [defendant's section 654 challenge to a negotiated lid sentence required a certificate of probable cause].)