California, United States of America
The following excerpt is from People v. Longoria, H045593 (Cal. App. 2019):
Here, defendant's ineffective assistance of counsel claim is based on his trial counsel's failure to renew the suppression motion in the superior court prior to the entry of defendant's no contest plea. The substance of his claim is therefore a challenge to the validity of his plea. (See People v. Richardson (2007) 156 Cal.App.4th 574, 596.) Accordingly, defendant's ineffective assistance of counsel claim constitutes a certificate issue that must be rejected pursuant to section 1237.5 and the applicable rules because
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defendant failed to obtain a certificate of probable cause. (See Richardson, supra, at p. 596.)
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