You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

State ex rel. Mays v. State

Citation: 239 So. 3d 281Docket: No. 2017–KH–0323

Court: Supreme Court of Louisiana; April 6, 2018; Louisiana; State Supreme Court

Narrative Opinion Summary

The case involves an application for post-conviction relief by an individual convicted of Second Degree Murder and Armed Robbery, who alleged racial bias in his trial and jury selection processes. Filed on September 15, 2016, the application was denied as untimely, exceeding the two-year limit stipulated by Louisiana Code of Criminal Procedure Article 930.8, following the finalization of the conviction in 1993. The applicant raised five claims related to racial bias, but the court found insufficient factual support to meet exceptions outlined in the statute. The individual's application was further barred by procedural rules against successive applications, made mandatory by a 2013 amendment, as he had previously litigated at least six applications for post-conviction relief. The district court's denial, authored by Judge Ramona L. Emanuel on October 27, 2016, underscored the exhaustion of the applicant's right to state collateral review unless a narrow exception could be demonstrated. The court's decision mandated the recording of a minute entry and the dissemination of the opinion to all relevant parties, including the applicant, his custodian, and the District Attorney.

Legal Issues Addressed

Factual Support for Post-Conviction Claims

Application: The court found the applicant did not provide sufficient factual support for his claims to qualify for statutory exceptions.

Reasoning: The court found that Mays failed to provide sufficient factual support for his allegations that would qualify for the exceptions outlined in La.C.Cr.P. art. 930.8 (C. 1-4).

Successive Applications for Post-Conviction Relief

Application: Mays's successive application was barred due to procedural rules that prevent multiple filings unless specific exceptions are met.

Reasoning: Mays has fully litigated at least six applications for post-conviction relief, and because the procedural bars against successive filings were made mandatory by a 2013 amendment, he has exhausted his right to state collateral review unless he can demonstrate that a narrow exception applies.

Timeliness of Post-Conviction Relief Applications

Application: The court denied the application for post-conviction relief due to its untimeliness, as it was filed well beyond the two-year limitation period established by the relevant statute.

Reasoning: The application for post-conviction relief filed by Terry Wayne Mays on September 15, 2016, was denied due to untimeliness, as it was submitted well beyond the two-year limit established by La.C.Cr.P. art. 930.8 following the finalization of his conviction in 1993.