STATE v. SINGLETON (2021)

Supreme Court of Louisiana.2021-09-27No. No. 2021-KP-00325

Summary · law.co

Holding. The writ application was denied. The applicant exhausted his right to state collateral review and may not file further successive applications unless he satisfies one of the narrow exceptions specified in Louisiana law.

The applicant sought post-conviction relief through a writ application but failed to meet the legal standards required under Louisiana law. The court found that the applicant had not satisfied the burden of proof necessary for such relief and also lacked grounds for DNA testing as specified in the relevant statute.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether applicant satisfied the post-conviction burden of proof
Entitlement to DNA testing under Louisiana law
Restrictions on successive post-conviction applications
Exhaustion of state collateral review remedies

Procedural posture

The applicant filed a writ application seeking post-conviction relief after having already litigated two prior post-conviction applications in state court.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

Writ application denied. See per curiam.

Denied. Applicant fails to satisfy his post-conviction burden of proof. La.C.Cr.P. art. 930.2; see also State v. Pierre, 13-0873 (La. 10/15/13), 125 So.3d 403; State v. Conway, 01-2808 (La. 4/12/02), 816 So.2d 290.

Applicant also shows no entitlement to DNA testing. See La.C.Cr.P. art. 926.1. Applicant has now fully litigated two applications for 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 second or 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. Applicants claims have now been fully litigated in accord with La.C.Cr.P. art. 930.6, and this denial is final. Hereafter, unless he can show that one of the narrow exceptions authorizing the filing of a successive application applies, applicant has exhausted his right to state collateral review. The district court is ordered to record a minute entry consistent with this per curiam.