Does a defendant have to enter a motion to dismiss a motion where he entered a guilty plea because he was not advised of his right to appointed counsel?

People v. Howell (1986) 178 Cal.App.3d 268, held that the judgment resulting from defendant's guilty plea must be overturned because he was not advised of his right to appointed counsel at all stages of his case prior to his plea being entered. (Id. at pp. 273-276.) Again, it does not stand for the proposition advanced by petitioner. While the balance of the cases cited by petitioner reflect instances where dismissals were entered and affirmed, none support the conclusion that dismissal was required in this case as a matter of law. Structural error is found on very limited occasion in exceptional cases that render a trial fundamentally unfair as a vehicle for the determination of guilt or innocence. (People v. Mendoza (2016) 62 Cal.4th 856, 900.) This court has found no case law concluding that the absence of counsel at an initial arraignment constitutes structural error under every circumstance.