What is the test for issuing a certificate of probable cause under section 1237.5 of the California Criminal Code?

A trial court presented with an application for a certificate of probable cause must accede to that request if it presents an "arguably meritorious appeal." (People v. Holland (1978) 23 Cal.3d 77, 84.) "It is not the trial court's responsibility to determine [whether] there was an error in the proceedings. The trial court's sole objective is to eliminate those appeals `having no possible legal basis' . . . . 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." (Ibid.)