California, United States of America
The following excerpt is from People v. Hibbard, G053141 (Cal. App. 2016):
Counsel has suggested we consider whether Defendant knowingly, intelligently, and voluntarily waived his right to a contested hearing on the probation violation petition. The issue would have not merit. Defendant did not obtain a certificate of probable cause before filing the notice of appeal. (See People v. Panizzon (1996) 13 Cal.4th 68, 74, 78 [certificate of probable cause required to challenge validity of plea and sentence imposed in accordance with plea agreement]; People v. Sem, supra, 229 Cal.App.4th at pp. 1186-1187 [certificate of probable cause required to challenge validity of admission of probation violation].) Nothing in the record suggests that Defendant did not knowingly, intelligently, and voluntarily waive his right to a contested hearing on the probation violation petition.
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