California, United States of America
The following excerpt is from People v. Penkov, C075049 (Cal. App. 2016):
Because defendant's decision to plead no contest may have resulted from the denial of his motion to suppress, he must be allowed to withdraw his plea. (People v. Ruggles (1985) 39 Cal.3d 1, 13.) "Aside from the fact that the error is by its nature prejudicial, the concept of harmless error is irrelevant where, as here, a defendant pleads guilty or no contest after the erroneous denial of his suppression motion. [Citations.]" (People v. Ramirez (2006) 140 Cal.App.4th 849, 854.)
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