California, United States of America
The following excerpt is from People v. Macias, F064650 (Cal. App. 2013):
5. Claims involving denial of a discovery motion generally are not cognizable on appeal following a guilty or no contest plea. (See People v. Hunter (2002) 100 Cal.App.4th 37, 42.) Because defendant made a motion to suppress evidence, however, and the trial court's ruling on the Pitchess motion was intertwined with litigating the legality of the search and seizure in this case, we agree with the parties that defendant's Pitchess claim is properly before us, even without a certificate of probable cause. (See People v. Collins (2004) 115 Cal.App.4th 137, 150-151; People v. Hunter, supra, 100 Cal.App.4th at pp. 42-43; see also 1538.5, subd. (m).)
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.