In Young v. State, 8 S.W.3d 656 (Tex. Crim. App. 2000), the Court recognized that the 1977 amendment "authorized conditional appeals only in plea-bargained cases because a defendant who had no plea-bargain agreement with the State was still governed by the Helms Rule and could preserve issues for appeal only by pleading not guilty." Young, 8 S.W.3d at 666. The fact that under our interpretation of the proviso before Young, it operated to allow a greater opportunity for a plea-bargaining defendant to appeal than a non-plea-bargaining defendant who nevertheless entered a guilty plea runs counter to Monreal's argument. Under Young and current Rule 25.2(b), both bargaining and non-bargaining defendants can appeal rulings on written, pre-trial motions as well as jurisdictional issues. However, a non-bargaining defendant pleading guilty may be able to appeal an error not raised on a written pre-trial motion, if it is otherwise preserved and survives Young. A bargaining defendant would be required to obtain the trial court's consent to appeal the same issue. In this way, the consent requirement does limit a bargaining defendant's ability to appeal more than a non-bargaining defendant.