Opinion
No. 2016–KH–0272
08-04-2017
STATE EX REL. David A. LEE v. STATE of Louisiana
ON SUPERVISORY WRITS TO THE CRIMINAL DISTRICT COURT, PARISH OF ORLEANS
PER CURIAM:
Denied. The district court's minute entry provided sufficient notice of the court's denial of relator's documents motion. Cf. State ex rel. Foy v. Criminal Dist. Court , 96-0519, pp. 1-2 (La. 3/15/96), 669 So.2d 393.
Relator has exhausted his right to obtain post-conviction relief in state court. Similar to federal habeas relief, see 28 U.S.C. § 2244, Louisiana post-conviction procedure envisions the filing of a successive application only under the narrow circumstances provided in La.C.Cr.P. art. 930.4 and within the limitations period as set out in La.C.Cr.P. art. 930.8. Notably, the Legislature in 2013 La. Acts 251 amended that article to make the procedural bars against successive filings mandatory. Hereafter, unless he can show that one of the narrow exceptions authorizing the filing of a successive application applies, relator has exhausted his right to state collateral review. The district court is ordered to record a minute entry consistent with this per curiam.