What are the implications of a criminal conviction for a defendant's failure to obtain a certificate of probable cause?

California, United States of America


The following excerpt is from People v. Arnold, A131765 (Cal. App. 2011):

Appellant was sentenced to the term specified in his plea agreement and has not obtained a certificate of probable cause. Consequently, issues regarding the validity of his plea and the propriety of the sentence are not before us. (Pen. Code, 1237.5; People v. Panizzon (1996) 13 Cal.4th 68, 78.) As to other matters occurring after the plea was entered, the record does not reveal error entitling appellant to relief.

We are satisfied that appellant's appointed attorney has fully complied with the responsibilities of appellate counsel and that no arguable issues exist. (Smith v. Robbins (2000) 528 U.S. 259, 283.)

The judgment is affirmed.

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