Is a defendant's ineffective assistance of counsel claim a challenge to the validity of his no contest plea?

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 (1996) 13 Cal.4th 68, 76.)

Here, defendant's ineffective assistance of counsel claim is based on his trial counsel's failure to renew the suppression motion in the superior court prior to the entry of defendant's no contest plea. The substance of his claim is therefore a challenge to the validity of his plea. (See People v. Richardson (2007) 156 Cal.App.4th 574, 596.) Accordingly, defendant's ineffective assistance of counsel claim constitutes a certificate issue that must be rejected pursuant to section 1237.5 and the applicable rules because defendant failed to obtain a certificate of probable cause. (See Richardson, supra, at p. 596.)