California, United States of America
The following excerpt is from People v. Gray, F070151 (Cal. App. 2016):
However, issues going to the validity of a plea require compliance with section 1237.5 and a certificate of probable cause. (People v. Brown (2010) 181 Cal.App.4th 356, 359.) "Thus, for example, a certificate must be obtained when a defendant claims that a plea was induced by misrepresentations of a fundamental nature [citation] ...."
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(People v. Panizzon (1996) 13 Cal.4th 68, 76.) Defendant failed to obtain a certificate of probable cause and his issues are not cognizable on appeal.
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