Does Rule 31(d) allow an implied statement of grounds in some cases?

Even if the majority were correct in its conclusion that rule 31(d) allows an implied statement of grounds in some cases, the notice of appeal at issue in this case does not contain a sufficient implied statement. The notice of appeal's reference to "Rule 31(d)" is insufficient to demonstrate that this is a noncertificate appeal. As the majority explains (maj. opn., ante, at pp. 226-228 of 72 Cal.Rptr.2d, pp. 1193-1195 of 951 P.2d), the rule governs both certificate and noncertificate appeals. Nor does the additional reference to the "sentence" demonstrate that this is a noncertificate appeal. As the majority acknowledges (id. at p. 228 of 72 Cal.Rptr.2d, p. 1195 of 951 P.2d), some sentencing appeals do require certificates of probable cause. (See People v. Panizzon, supra, 13 Cal.4th 68, 51 Cal.Rptr.2d 851, 913 P.2d 1061.) ²