Can a defendant appeal from a conviction predicated on a no contest plea?

"Under section 1237.5, an appeal from a conviction predicated on a [no contest plea] requires a certificate of probable cause. 'Notwithstanding the broad language of section 1237.5, it is settled that two types of issues may be raised in a guilty or nolo contendere plea appeal without issuance of a certificate: (1) search and seizure issues for which an appeal is provided under section 1538.5, subdivision (m); and (2) issues regarding proceedings held subsequent to the plea for the purpose of determining the degree of the crime and the penalty to be imposed.'" (People v. Richardson, supra, 156 Cal.App.4th at p. 596.)

Thus, absent a certificate of probable cause, we can address the ineffective assistance of counsel claim only if it pertains to "'proceedings held subsequent to the plea for the purpose of determining the degree of the crime and the penalty to be imposed.'" (People v. Richardson, supra, 156 Cal.App.4th at p. 596.) Here, if defendant's trial attorney erred in failing to preserve the Fourth Amendment issue for our review,

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