requirements for filing such a petition. See id. at 148. Although the state had “announced strict rules regarding the granting of second and subsequent ... petitions,” id., the Third Circuit did not consider whether Lovasz’s petition satisfied those rules before concluding that the petition was “properly filed.” In short, the court did not review the merits of the petition. This case is indistinguishable from Lo-vasz. Like Pennsylvania, Washington recognizes exceptions to its bar against successive petitions, see Wash. Rev.Code § 10.72.140, as well as exceptions to its one-year time limit for filing petitions for post-conviction review, see Wash. Rev. Code § 10.73.100. Dictado invoked one of those exceptions: he claimed his petition was based on newly discovered ev .D.Tex.1998) (<HOLDING>); Hughes v. Irvin, 967 F.Supp. 775, 778-79
holding that petition was properly filed even though the state court denied it as procedurally barred because the petition was delivered to and accepted by the state court holding that seventh application for postconviction relief which was rejected because evidence on which it was based was not properly authenticated was properly filed holding that second state petition for postconviction relief that was dismissed as frivolous and patently without merit was properly filed holding that a second or subsequent state petition for postconviction relief filed according to the procedural rules of the state constitutes a properly filed application  without regard to the merits of the petition holding that second state petition for postconviction relief that was dismissed as an abuse of the writ was properly filed