California, United States of America
The following excerpt is from People v. Erwin, C079585 (Cal. App. 2016):
A defendant challenging the factual basis for her no contest plea " 'is properly viewed as [challenging] the validity of the plea itself.' [Citation.]" (People v. Zuniga (2014) 225 Cal.App.4th 1178, 1187.) Because defendant failed to obtain a certificate of probable cause as required under section 1237.5, her challenge is barred.
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