The subchapter is the exclusive means to challenge a conviction in Michigan once a defendant has exhausted the normal appellate process." People v. Reed, 198 Mich. App. 639, 642, 499 N.W.2d 441, 443 (1993) (emphasis added), aff'd, 449 Mich. 375, 535 N.W.2d 496 (1995); see also Peterson v. Klee, 655 F. App'x 327, 331 (6th Cir. 2016) ("[U]nlike someone pursuing a direct appeal as of right, a defendant seeking appellate review of the denial of a motion for relief from judgment under MCR 6.500 must apply for leave to appeal, does not receive the benefit of oral argument at the leave stage, and does not have the right to appointed counsel."); Taylor v. Smith, No. 14-175, 2016 WL 6275345, at *1 (W.D. Mich. Oct. 27, 2016) ("A 6.500 motion is [not] a direct appeal.").
" Holt v. Bowersox, 191 F.3d 970, 974 (8th Cir. 1999) (citations omitted).Peterson v. Klee, No. 2:12-CV-11109, 2015 WL 4389785, at *8 (E.D. Mich. July 15, 2015), aff'd on other grounds, 655 F. App'x 327 (6th Cir. 2016), cert. denied, 137 S. Ct. 1222 (2017). Several other district courts in this circuit have also applied the Eighth Circuit's "conclusive showing" requirement.