Does a plea of no contest preclude appellate review of the denial of a motion to disclose the sealed portion of the search warrant affidavit and discover the identity of a confidential informant?

California, United States of America


The following excerpt is from People v. Hobbs, 30 Cal.Rptr.2d 651, 7 Cal.4th 948, 873 P.2d 1246 (Cal. 1994):

At the outset we must determine whether defendant's plea of no contest precludes appellate review of the denial of her motions to disclose the sealed portion of the search warrant affidavit and discover the identity of the confidential informant. "Issues cognizable on an appeal following a guilty [or no contest] plea are limited to issues based on 'reasonable constitutional, jurisdictional, or other grounds going to the legality of the proceedings' resulting in the plea." (People v. DeVaughn (1977) 18 Cal.3d 889, 895-896, 135 Cal.Rptr. 786, 558 P.2d 872; see Pen.Code, 1237.5.)

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