California, United States of America
The following excerpt is from People v. Hopkins, B246160 (Cal. App. 2013):
"In determining whether section 1237.5 applies to a challenge of a sentence imposed after a plea of guilty or no contest, courts must look to the substance of the appeal: 'the crucial issue is what the defendant is challenging, not the time or manner in which the challenge is made.' [Citation.] Hence, the critical inquiry is whether a challenge to the sentence is in substance a challenge to the validity of the plea, thus rendering the appeal subject to the requirements of section 1237.5." (People v. Panizzon, supra, 13 Cal.4th at p. 76.) The certificate requirements of section 1237.5 "should be applied in a strict manner." (People v. Mendez, supra, 19 Cal.4th at p. 1098.)
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