California, United States of America
The following excerpt is from People v. Saunders, 232 Cal.App.3d 1592, 284 Cal.Rptr. 212 (Cal. App. 1991):
Appellant filed a timely notice of appeal. Although no certificate of probable cause was included in the notice of appeal ( 1237.5), such a certificate is not required because the only area of contention is sentencing error. (People v. Sumstine (1984) 36 Cal.3d 909, 915, fn. 3, 206 Cal.Rptr. [232 Cal.App.3d 1595] 707, 687 P.2d 904; People v. Garner (1985) 165 Cal.App.3d 145, 150, 211 Cal.Rptr. 267.)
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