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State ex rel. Lay v. State

Citations: 181 So. 3d 693; 2015 La. LEXIS 2619; 2015 WL 8676660Docket: No. 2014-KH-2549

Court: Supreme Court of Louisiana; November 5, 2015; Louisiana; State Supreme Court

Narrative Opinion Summary

Relator's application for reconsideration of post-conviction relief, previously denied, is denied again. Relator has fully litigated his application in state court. Under Louisiana law, specifically La.C.Cr.P. art. 930.4 and La.C.Cr.P. art. 930.8, a second or successive application for post-conviction relief can only be filed under narrow circumstances. The 2013 amendment to La.C.Cr.P. art. 930.4 established mandatory procedural bars against such filings. Relator's claims have been fully addressed in state collateral proceedings as per La.C.Cr.P. art. 930.6, rendering this denial final. Relator may only pursue further applications if he can demonstrate that one of the specific exceptions for successive filings applies. The District Court is instructed to document a minute entry reflecting this decision.

Legal Issues Addressed

Documentation of Judicial Decisions

Application: The District Court is required to create a minute entry to document the decision regarding the denial of the relator's application for post-conviction relief.

Reasoning: The District Court is instructed to document a minute entry reflecting this decision.

Finality of State Court Decisions on Post-Conviction Relief

Application: The court's decision to deny the application is final as the relator's claims have already been addressed in state collateral proceedings, and no applicable exceptions for further filings are demonstrated.

Reasoning: Relator's claims have been fully addressed in state collateral proceedings as per La.C.Cr.P. art. 930.6, rendering this denial final.

Limitations on Successive Applications for Post-Conviction Relief

Application: The court denies the relator's successive application for post-conviction relief, as it does not meet the narrow circumstances under which such applications are permissible.

Reasoning: Under Louisiana law, specifically La.C.Cr.P. art. 930.4 and La.C.Cr.P. art. 930.8, a second or successive application for post-conviction relief can only be filed under narrow circumstances.

Procedural Bars on Successive Post-Conviction Relief Applications

Application: The relator's application is denied due to the procedural bars established by the 2013 amendment to La.C.Cr.P. art. 930.4, which prevents successive filings unless certain exceptions are met.

Reasoning: The 2013 amendment to La.C.Cr.P. art. 930.4 established mandatory procedural bars against such filings.