California, United States of America
The following excerpt is from The People v. Davenport, Los Angeles County Super. Ct. No. GA077179, NO. B222670 (Cal. App. 2011):
2.Appellant is not required to have obtained a certificate of probable cause because she challenges only the restitution order, which was issued after she pled guilty, and does not challenge the validity of the plea. (See 1237.5; People v. French (2008) 43 Cal.4th 36, 45 ["the certificate requirement does not apply when the defendant assert[s] only that errors occurred in the... adversary hearings conducted by the trial court for the purpose of determining the degree of the crime and the penalty to be imposed.' [Citation.]"].)
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