Does a defendant need to obtain a certificate of probable cause to challenge their sentence?

Defendant's failure to obtain a certificate of probable cause does not effect a forfeiture. A certificate of probable cause is not required when an "appeal is based on '[g]rounds that arose after entry of the plea and do not affect the plea's validity.' " (People v. Rabanales (2008) 168 Cal.App.4th 494, 500.) Defendant does not challenge her plea's validity; she challenges the manner of its enforcement. Thus, her challenge does not require a certificate of probable cause.

Similarly, defense counsel's failure to object at sentencing does not bar defendant's claim. Failure to object at sentencing does not forfeit a defendant's right to the benefit of her bargain, if a complete Penal Code section 1192.5 admonishment was not given. (People v. Victorian (1992) 2 Cal.App.4th 954, 958 fn. 5.) To the extent defendant challenges her sentence as unauthorized under the agreement, her claim is not forfeited because she was never advised pursuant to Penal Code section 1192.5.