The California Supreme Court reversed a decision of the court of appeal. The court held that a defendant who is tried and convicted following a plea of not guilty does not need a certificate of probable cause to appeal his or her admission of a sentencing allegation.
William Maultsby was convicted by a jury of a petty theft offense, but admitted a prior felony conviction. He later appealed only his admission of the prior conviction. The court of appeal dismissed the appeal, finding that Maultsby was not permitted to appeal his admission of the prior felony conviction without first obtaining a certificate of probable cause, which he had not done.
