California, United States of America
The following excerpt is from People v. Aber, G054054 (Cal. App. 2017):
In fact, without a certificate of probable cause, appellant may obtain review solely of so-called "noncertificate" issues. These are "postplea questions not challenging his plea's validity and/or questions involving a search or seizure whose lawfulness was contested pursuant to [Penal Code] section 1538.5[.]" (People v. Mendez, supra, 19 Cal.4th at p. 1088.)
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