California, United States of America
The following excerpt is from People v. Cooley, C077161 (Cal. App. 2015):
In his reply brief, defendant argues that no certificate of probable cause is required because his sentence is unauthorized, and therefore subject to judicial correction at any time. The Fourth District Court of Appeal recently considered the same argument in People v. Zuniga (2014) 225 Cal.App.4th 1178, at page 1186 (Zuniga).
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