In 2008, the court revoked Ponsart's probation and sentenced him to an aggravated prison term of fifteen years. We affirmed Ponsart's sentence on appeal. State v. Ponsart, 224 Ariz. 518, ¶ 16, 233 P.3d 631, 636 (App. 2010). ¶2 Ponsart then filed a notice of post-conviction relief, followed by a pro se petition in which he indicated, without further explanation, that he was entitled to relief based on "[t]he unconstitutional suppression of evidence by the state," "[t]he unconstitutional use by the state of perjured testimony," and "[v]iolation of the right not to be placed twice in jeopardy for the same offense.

Regenold appealed. Citing A.R.S. § 13-4033(B), the court of appeals dismissed the appeal for lack of jurisdiction, finding that Regenold's sentence had been imposed pursuant to his plea agreement and, therefore, rather than appealing, he should have filed a petition for post-conviction relief pursuant to Rule 32. State v. Regenold, 1 CA-CR 08-0651, 2010 WL 987063 (Ariz.App. Mar. 18, 2010). ¶ 4 We granted review of Regenold's petition for review because the court of appeals decision in this case conflicts with the opinion of the court of appeals in State v. Ponsart, 224 Ariz. 518, 233 P.3d 631 (App. 2010), and the issue presented is of statewide importance. We have jurisdiction under Article 6, section 5, clause 3 of the Arizona Constitution.

¶5 We lack jurisdiction to consider a defendant's direct appeal from a judgment or sentence entered pursuant to a plea agreement. A.R.S § 13-4033(B); State v. Regenold, 226 Ariz. 378, 378, ¶ 1 (2011); State v. Ponsart, 224 Ariz. 518, 521, ¶ 9 (App. 2010). Similarly, a defendant may not directly appeal from a revocation of probation when he or she admits to violating a probation condition.

But with two exceptions, see infra ¶¶ 13–14, none of the cases Hoffman cites concerned a challenge to an order entered as a direct consequence of a plea agreement's terms. See Regenold, 226 Ariz. at 380 ¶ 12, 249 P.3d at 339 (reviewing sentence imposed as consequence of a contested probation violation); State v. Ponsart, 224 Ariz. 518, 521–22 ¶¶ 2–12, 233 P.3d 631, 634–35 (App.2010) (same); State v. Delgarito, 189 Ariz. 58, 59, 938 P.2d 107, 108 (App.1997) (involving a challenged order designating an offense as a felony although offense left undesignated at time of guilty plea and disposition). Moreover, since 1992, appellate courts have routinely dismissed appeals of post-judgment orders that challenged plea agreement terms.

Moreover, the court's finding of emotional harm was reasonably supported by B.'s statements during Coates's original sentencing hearing and at the probation revocation proceedings. See State v. Ponsart, 224 Ariz. 518, ¶ 15, 233 P.3d 631, 635 (App. 2010) (we defer to trial court's factual findings supported by record and not clearly erroneous). ¶24 Finally, the sentence imposed was within the statutory range, see A.R.S. § 13-702(D) (1.5 years maximum sentence for first-time offenders convicted of class-six felony), and the probation violations were similar in nature to the underlying offenses, see Baum, 182 Ariz. at 140, 893 P.2d at 1303 (probation violation may be aggravating sentencing factor if demonstrates defendant's failure to "'avail himself of the opportunity to reform'"), quoting State v. Rowe, 116 Ariz. 283, 284, 569 P.2d 225, 226 (1977).

Generally, an order made after judgment may be appealable if it addresses an issue that would not arise in a review of the conviction and sentence. See State v. Ponsart, 224 Ariz. 518, ¶ 10 (App. 2010); see also State v. Delgarito, 189 Ariz. 58, 59 (App. 1997) (order must not "effectively challenge[] [a] plea agreement or sentence").¶6 The order in question falls squarely into this category.

21(A)(1) (2003), 13-4033(A)(3), (4) (2010). See State v. Regenold, 226 Ariz. 378, 380, ¶ 12 (2010) (determining A.R.S. § 13-4033(B) did not preclude an appeal from a contested probation revocation and leaving open the possibility that A.R.S. § 13-4033(A)(3) or (A)(4) provides jurisdiction); State v. Ponsart, 224 Ariz. 518, 519-22, ¶¶ 2-12 (App. 2010) (stating any defendant may appeal a contested finding that probation was violated, and determining in appeal from probation revocation that A.R.S. § 13-4033(A)(3) or (A)(4) provided jurisdiction). DISCUSSION