California, United States of America
The following excerpt is from People v. Shelton, 125 P.3d 290, 37 Cal.Rptr.3d 354 (Cal. 2006):
The crucial question here, disputed by the parties, is whether defendant's sentence challenge based on Penal Code section 654's prohibition against multiple punishment is a challenge that affects the validity of his no contest pleas. "[A] challenge to a negotiated sentence imposed as part of a plea bargain is properly viewed as a challenge to the validity of the plea itself" and thus requires a certificate of probable cause. (People v. Panizzon (1996) 13 Cal.4th 68, 79, 51 Cal.Rptr.2d 851, 913 P.2d 1061.)
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