Jason Donald Matakis v. State of Minnesota
2015 Minn. LEXIS 187
Minn.2015Background
- Jason Matakis pleaded Alford guilty to one count of first-degree criminal sexual conduct and was sentenced to the mandatory 144-month prison term.
- The underlying allegations arose from a 13-year-old’s statement describing repeated sexual acts when she was 9–11; Matakis admitted some sexual touching to investigators but denied penetration.
- Matakis filed a postconviction petition, just before the 2-year statutory deadline, alleging his plea was not knowing, voluntary, or intelligent; the petition contained no factual allegations or supporting documents and promised later submissions.
- The postconviction court denied the petition without an evidentiary hearing, finding it failed to meet statutory content requirements.
- The Minnesota Court of Appeals affirmed; the Minnesota Supreme Court granted review and likewise affirmed, holding the postconviction court did not abuse its discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether petition alleging invalid plea required an evidentiary hearing | Matakis: court should have given notice/opportunity to supply promised facts and hold a hearing before dismissal | State: petition lacked any factual support; transcript showed no basis for relief; dismissal was proper without hearing | Held: No hearing required where petition contains no factual allegations that, if proved, would entitle petitioner to relief; denial affirmed |
| Whether the postconviction court abused discretion by dismissing without notice or chance to amend (sua sponte) | Matakis: dismissal deprived him of his one review and was sua sponte without notice; court should have set a deadline for amendment | State: petition was deficient; State argued denial on merits; court was not acting without prompting and Matakis had notice via his promise to supplement | Held: Not an abuse of discretion; court could dismiss a petition that fails statutory requirements without providing further opportunity |
| Whether the Alford plea had an adequate factual basis | Matakis: questions about accuracy of factual basis support invalid plea claim | State: plea transcript and Matakis’s acknowledgments provided sufficient factual basis | Held: Record shows prosecutor and judge discussed evidence and Matakis acknowledged the State would have sufficient evidence; factual basis adequate |
| Whether lack of direct appeal compels more leniency in postconviction pleading requirements | Matakis: absent direct appeal, he should get opportunity to amend and one review | State: procedural requirements of the Post-Conviction Remedy Act still apply regardless of direct appeal | Held: Lack of direct appeal does not excuse compliance with postconviction statute; requirements enforced |
Key Cases Cited
- State v. Ecker, 524 N.W.2d 712 (Minn. 1994) (elements of valid guilty plea: accurate, voluntary, intelligent)
- Fratzke v. State, 450 N.W.2d 101 (Minn. 1990) (no evidentiary hearing where allegations are too generalized)
- Townsend v. State, 582 N.W.2d 225 (Minn. 1998) (summary denial appropriate for unsupported general allegations)
- Hodgson v. State, 540 N.W.2d 515 (Minn. 1995) (petitioner’s allegations must be more than argumentative assertions)
- State v. Theis, 742 N.W.2d 643 (Minn. 2007) (factual-basis standards for Alford pleas and better practice to place evidence on the record)
- Riley v. State, 819 N.W.2d 162 (Minn. 2012) (petition must be construed liberally, but dismissal is appropriate when no material facts are alleged)
- State v. Trott, 338 N.W.2d 248 (Minn. 1983) (accuracy requirement protects defendants from pleading to greater offenses than proof supports)