California, United States of America
The following excerpt is from The People v. Rodriguez, D055974, No. JCF22499 (Cal. App. 2010):
Rodriguez's certificate of probable cause does not change this result." 'The impact of section 1237.55 relates to the procedure in perfecting an appeal from a judgment based on a plea of guilty, and not to the grounds upon which such an appeal may be taken.' " [Citation.] (People v. Hoffard, supra, 10 Cal.4th at p. 1178.) Issuance of a certificate of probable cause "cannot expand the scope of review to include a noncognizable issue." (Ibid.)
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