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State v. Claude

Citation: 241 So. 3d 299Docket: No. 2018–KH–0218

Court: Supreme Court of Louisiana; April 16, 2018; Louisiana; State Supreme Court

Narrative Opinion Summary

Writ not considered due to untimeliness in accordance with La.S.Ct. Rule X.5. Relator has exhausted his right to post-conviction relief in state court. Louisiana's post-conviction procedure permits a second or successive application only under specific circumstances outlined in La.C.Cr.P. art. 930.4 and within the limitations of La.C.Cr.P. art. 930.8. Following the 2013 amendment (La. Acts 251), procedural bars against successive filings are mandatory. The relator's application for post-conviction relief was denied by the District Court, making that ruling final. The relator may only pursue a successive application if he can demonstrate that one of the limited exceptions applies. The District Court is directed to record a minute entry reflecting this decision.

Legal Issues Addressed

Exhaustion of Post-Conviction Relief Rights

Application: The relator has fully utilized his right to post-conviction relief within the state court system, precluding further relief unless specific exceptions apply.

Reasoning: Relator has exhausted his right to post-conviction relief in state court.

Finality of District Court's Denial of Post-Conviction Relief

Application: The denial of the relator's application for post-conviction relief by the District Court is final, unless he can prove that an exception to the procedural bars applies.

Reasoning: The relator's application for post-conviction relief was denied by the District Court, making that ruling final.

Limitations on Successive Post-Conviction Applications

Application: Under Louisiana post-conviction procedures, a second or successive application is restricted and must meet certain criteria to be considered, particularly following the 2013 amendments.

Reasoning: Louisiana's post-conviction procedure permits a second or successive application only under specific circumstances outlined in La.C.Cr.P. art. 930.4 and within the limitations of La.C.Cr.P. art. 930.8.

Mandatory Procedural Bars Post-2013 Amendment

Application: The 2013 amendment mandates that procedural bars against successive filings must be applied, thus limiting the relator's ability to pursue further relief.

Reasoning: Following the 2013 amendment (La. Acts 251), procedural bars against successive filings are mandatory.

Requirement for District Court Record Keeping

Application: The District Court is instructed to document the decision regarding the relator's post-conviction relief application in the official court records.

Reasoning: The District Court is directed to record a minute entry reflecting this decision.

Untimeliness and Procedural Bars under La.S.Ct. Rule X.5

Application: The writ was not considered due to the relator's failure to meet the timing requirements set forth in the rule, rendering the application untimely.

Reasoning: Writ not considered due to untimeliness in accordance with La.S.Ct. Rule X.5.