What is the legal test for appealing a judgment of conviction arising out of a guilty plea?

A defendant is generally precluded from appealing a judgment of conviction arising out of his guilty plea unless he has applied to the trial court for and received a certificate of probable cause permitting such an appeal. ( 1237.5.) Although the certificate requirement is strictly applied (People v. Mendez (1999) 19 Cal.4th 1084, 1097), a defendant is permitted to appeal following a guilty plea without the need for a certificate of probable cause to raise issues relating to (1) the validity of a search and seizure and (2) "proceedings held subsequent to the plea for the purpose of determining the degree of the crime and the penalty to be imposed." (People v. Shelton (2006) 37 Cal.4th 759, 766, quoting People v. Buttram (2003) 30 Cal.4th 773, 780; see also Cal. Rules of Court, rule 8.304(b)(4)(B) [requiring a certificate of probable cause unless the notice of appeal is based on "[g]rounds that arose after entry of the plea and do not affect the plea's validity"].)