California, United States of America
The following excerpt is from People v. Powell, A140738 (Cal. App. 2014):
Appellant contends no certificate of probable cause is required for the present appeal. He argues he is not attacking the validity of the plea "but instead, is challenging only the failure of the trial court to remove defense counsel on its own motion." However, the underlying premise of appellant's claim is that defense counsel should have been removed because appellant's conflict with counsel and/or counsel's ineffectiveness undermined the validity of the plea. Appellant does not argue the trial court's failure to remove defense counsel had any impact on sentencing, and he fails to provide any reasoned argument or cite any authority that a certificate of probable cause is unnecessary in the circumstances of the present case. (See People v. Stubbs (1998) 61 Cal.App.4th 243, 244-245 [claim based on counsel's performance prior to the entry of the plea attacks
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