California, United States of America
The following excerpt is from People v. Garcia, F063103 (Cal. App. 2013):
7. Defendant's challenge to the court's restitution order is "based solely on grounds occurring after entry of the plea[] and [does] not affect [its] validity; therefore, no certificate [of probable cause] is required. [Citation.]" (People v. Kunitz (2004) 122 Cal.App.4th 652, 658.)
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