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State ex rel. Oxley v. State

Citations: 224 So. 3d 961; 2017 La. LEXIS 1939; 2017 WL 4103764Docket: No. 2017-KH-1215

Court: Supreme Court of Louisiana; September 15, 2017; Louisiana; State Supreme Court

Narrative Opinion Summary

The supervisory writ filed by the relator to the Eleventh Judicial District Court, Parish of Sabine, is not considered due to being untimely under La.S.Ct. R. X. 5. The relator has exhausted the right to seek post-conviction relief in state court. Louisiana's post-conviction procedures, similar to federal habeas relief (28 U.S.C. 2244), allow for a second or successive application only under specific narrow circumstances outlined in La. C.Cr. P. art. 930.4 and within the time limitations set by La. C.Cr. P. art. 930.8. The 2013 amendment (La. Acts 251) established mandatory procedural bars against successive filings. Since the district court has already denied the relator’s application for post-conviction relief, that ruling is final. The relator can only pursue a successive application if one of the narrow exceptions applies. The district court is instructed to make a minute entry reflecting this decision.

Legal Issues Addressed

District Court's Role in Successive Applications

Application: The district court must document the decision and can only accept a successive application if it falls within the narrow exceptions.

Reasoning: The district court is instructed to make a minute entry reflecting this decision.

Exhaustion of Post-Conviction Relief

Application: The relator has no further right to seek post-conviction relief in state court as the application has already been denied and is considered final.

Reasoning: The relator has exhausted the right to seek post-conviction relief in state court.

Finality of District Court Decision

Application: The district court's denial of the relator's application for post-conviction relief is a final ruling.

Reasoning: Since the district court has already denied the relator’s application for post-conviction relief, that ruling is final.

Procedural Bars to Successive Filings

Application: The 2013 amendment (La. Acts 251) imposes mandatory procedural bars against successive post-conviction relief filings unless specific exceptions apply.

Reasoning: The 2013 amendment (La. Acts 251) established mandatory procedural bars against successive filings.

Successive Post-Conviction Applications

Application: Under Louisiana's post-conviction procedures, a successive application is permitted only under specific narrow circumstances.

Reasoning: Louisiana's post-conviction procedures, similar to federal habeas relief (28 U.S.C. 2244), allow for a second or successive application only under specific narrow circumstances outlined in La. C.Cr. P. art. 930.4 and within the time limitations set by La. C.Cr. P. art. 930.8.

Timeliness of Supervisory Writs

Application: The supervisory writ filed by the relator was dismissed due to untimeliness according to Louisiana Supreme Court Rule X, Section 5.

Reasoning: The supervisory writ filed by the relator to the Eleventh Judicial District Court, Parish of Sabine, is not considered due to being untimely under La.S.Ct. R. X. 5.