People v. Buttram

Opinion

BAXTER, J.

We address a conflict in the Courts of Appeal about the proper application of Penal Code section 1237.5 and rule 31(d) of the California Rules of Court.1 These provisions allow an appeal from a judgment entered on a guilty plea only if (1) the defendant obtains a certificate of probable cause from the trial court or (2) the appeal falls within the two categories of grounds that do not require a certificate. One “noncertificate” category involves postplea claims, including sentencing issues, that do not attack the validity of the plea.

In People v. Panizzon (1996) 13 Cal.4th 68…