What is the test for obtaining a certificate of probable cause to appeal a $50,000 fine?

We begin with the People's motion to dismiss defendant's appeal on the ground that he did not obtain a certificate of probable cause. It is well settled that appeal of a restitution fine imposed after a guilty plea does not affect the validity of a guilty plea and no certificate of probable cause is required. (People v. Kunitz (2004) 122 Cal.App.4th 652, 657-658.) Here, defendant's guilty plea was entered on May 5, 2011. The challenged fines were imposed over one year later, on November 16, 2012. Accordingly, no certificate of probable cause was required and the People's motion is denied.