What is the test for issuing a certificate of probable cause in a criminal case?

In deciding whether to issue a certificate of probable cause, "[t]he trial court is empowered to review the statement of the grounds of the appeal to preclude those appeals which raise no issues cognizable after a guilty plea or which raise cognizable issues which are 'clearly frivolous and vexatious . . . .' [Citations.] It is not the trial court's responsibility to determine if there was an error in the proceedings. . . . The trial court's sole objective is to eliminate those appeals 'having no possible legal basis' by refusing to issue a certificate of probable cause. [Citations.] Section 1237.5 requires the trial court to certify any arguably meritorious appeal to the appellate courts. Thus, if the statement submitted by the defendant in accordance with section 1237.5 presents any cognizable issue for appeal which is not clearly frivolous and vexatious, the trial court abuses its discretion if it fails to issue a certificate of probable cause. [Citations.]" (People v. Holland (1978) 23 Cal.3d 77, 83-84, disagreed with on other grounds in People v. Mendez (1999) 19 Cal.4th 1084, 1093-1099 & fn. 7.) The propriety of a trial court's

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