People v. Jones

Opinion

WERDEGAR, J.

Under California Rules of Court, rule 31(d), 1 an appeal taken from a conviction obtained by plea of guilty or nolo contendere is “operative” without issuance of a certificate of probable cause (Pen. Code, § 1237.5) 2 only if the notice of appeal states the appeal is based on either of two broad categories of grounds not requiring a certificate: those involving postplea proceedings and not challenging the validity of the plea, or those involving the validity of a search or seizure previously challenged under section 1538.5 (sometimes collectively referred to here as…