California, United States of America
The following excerpt is from The People v. Carver, B225486, Super. Ct. No. PA065445 (Cal. App. 2011):
Appellant did not obtain a certificate of probable cause. Hence, he cannot raise any claim going to the validity of his no contest plea. This would include his claim that he was coerced into pleading no contest by his attorney and his claim that the trial court should have vacated his plea. With respect to appellant's challenge to the denial of his motion to withdraw his plea on the grounds that it was obtained by duress, the fact that the motion was a post-plea proceeding does not remove it from the requirements of section 1237.5 where the motion relates to the validity of the plea. (People v. Ribero (1971) 4 Cal.3d 55, 62-64.) To the extent his claim may be construed as a challenge to the effectiveness of his counsel in representing him, that claim clearly involves evidence outside of the record below, including the DVD he submitted to us, and is more appropriately raised by petition for writ of habeas corpus. (People v. Avena (1996) 13 Cal.4th 394, 419.)
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