California, United States of America
The following excerpt is from People v. Cooke, 111 Cal.App.4th 447, 3 Cal.Rptr.3d 557 (Cal. App. 2003):
The Attorney General submits this issue is not cognizable on appeal because defendant did not obtain a certificate of probable cause. He argues that defendant is in effect challenging the validity of his plea, so a certificate of probable cause is required. (People v. Panizzon (1996) 13 Cal.4th 68, 76, 51 Cal.Rptr.2d 851, 913 P.2d 1061.)
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