Matakis v. State
842 N.W.2d 689
Minn. Ct. App.2014Background
- Jason Matakis pleaded guilty (Alford plea) in 2011 to one count of criminal sexual conduct based on recorded admissions and victim/family statements; sentenced to a 144-month mandatory minimum.
- He did not file a direct appeal and instead filed a postconviction petition on May 8, 2013, just inside the two-year statutory window for postconviction relief.
- The petition alleged Matakis’s plea was not "knowing, voluntary, or intelligent," but contained no factual allegations supporting that claim—only a promise to supply facts and an affidavit later.
- Counsel asserted scheduling conflicts with the correctional facility prevented meeting Matakis and finalizing supporting materials before filing.
- The postconviction court summarily dismissed the petition without an evidentiary hearing, concluding the petition failed to allege facts as required by statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the postconviction court abused its discretion by denying relief without a hearing where the petition promised facts later | Matakis: petition was timely and alleged involuntariness; counsel’s inability to meet justified lack of factual detail | State: petition lacked the statutorily required statement of facts; a mere promise to provide facts later is insufficient | Court: No abuse of discretion; petition failed to allege facts that, if true, would entitle relief, so dismissal without hearing was proper |
| Whether prison scheduling conflicts excuse failure to plead factual basis | Matakis: scheduling conflicts made meeting and specifying facts unreasonable | State: two-year statutory period was ample time; conflicts do not trigger exception | Court: Scheduling conflicts do not excuse the statutory pleading requirement; no exception applied |
| Whether denial without hearing deprived Matakis of appellate review because he did not appeal directly | Matakis: he effectively relied on postconviction relief as his appeal and denial without hearing hurts appellate rights | State: choosing postconviction relief carries statutory obligations; failure to comply defeats the petition | Court: A postconviction petition is subject to the statute’s requirements; failure to plead facts defeats the claim |
Key Cases Cited
- Sontoya v. State, 829 N.W.2d 602 (Minn. 2013) (standard of review for postconviction denials)
- Knaffla v. State, 243 N.W.2d 737 (Minn. 1976) (petitioners must comply with postconviction statute)
- Fratzke v. State, 450 N.W.2d 101 (Minn. 1990) (no hearing where petition lacks facts that would entitle relief)
- Hodgson v. State, 540 N.W.2d 515 (Minn. 1995) (denial proper where petition rests on unsupported assertions)
- Townsend v. State, 582 N.W.2d 225 (Minn. 1998) (summary denial appropriate when only general allegations presented)
- Brown v. State, 449 N.W.2d 180 (Minn. 1989) (guilty pleas may be challenged postconviction but petitioner must show plea was not knowing, voluntary, intelligent)
- Bruestle v. State, 719 N.W.2d 698 (Minn. 2006) (no hearing where petitioner offers no evidentiary support for incompetence claim)
- Deegan v. State, 711 N.W.2d 89 (Minn. 2006) (postconviction relief can serve as the single appeal by right but is subject to statutory requirements)