Patrick Samuel Meszaros v. State of Minnesota, A16-76

Background

In 2008 Meszaros fled police, struck parked cars, and police found ~58.89 grams of methamphetamine; he was charged with first-degree controlled-substance crime and fleeing in a motor vehicle.
On Nov. 13, 2008 Meszaros pleaded guilty to fleeing and to a reduced charge of second-degree controlled-substance crime; he received concurrent sentences (92 months and 17 months).
He did not pursue a direct appeal. Sentence was imposed Jan. 21, 2009.
In July 2014 (almost six years later) Meszaros sought postconviction relief to withdraw his guilty plea, asserting newly discovered systemic reliability failures at the St. Paul Police Department Crime Lab (SPPDCL).
The district court denied the petition as untimely and rejected exceptions to the two-year statute of limitations and claims of manifest injustice, Brady/ due-process violations, and ineffective assistance of counsel. Meszaros appealed.
The Court of Appeals affirmed, holding (as in Roberts) that Meszaros could have discovered lab issues pre-plea, failed to show actual innocence or other grounds to excuse timeliness, and waived many post-plea challenges.

Issues

Issue	Meszaros' Argument	State's Argument	Held
Whether postconviction petition was timely or excused by the newly-discovered-evidence exception	Lab reliability failures at SPPDCL are newly discovered scientific evidence that could not have been discovered with due diligence and establish innocence	Meszaros knew case rested on lab results and could have pursued discovery before pleading; he offered no clear-and-convincing proof of innocence	Denied — exception does not apply; petition untimely
Whether interests-of-justice exception excuses untimeliness	Exceptional lab failures justify equitable tolling in the interests of justice	No exceptional circumstances—Meszaros had opportunity to investigate, made a voluntary plea, and no fundamental unfairness or judicial-integrity concern shown	Denied — exception does not apply
Whether plea was manifestly unjust (invalid) — accuracy, voluntariness, intelligence	Plea was induced by claim of credible lab testing and thus may be inaccurate/involuntary/ unintelligent	Plea colloquy and plea petition show Meszaros was informed of rights, waived them knowingly, and accuracy standard is satisfied for a plea	Denied — plea was accurate, voluntary, and intelligent
Whether counsel was ineffective for failing to obtain SPPDCL underlying files	Trial counsel should have demanded and reviewed SPPDCL files; failing to do so was deficient	No factual basis provided to challenge results; investigation was strategic and not shown unreasonable or prejudicial	Denied — no ineffective-assistance established

Key Cases Cited

Roberts v. State, 856 N.W.2d 287 (Minn. App. 2014) (addressing untimeliness of postconviction plea-withdrawal claims based on SPPDCL deficiencies)
Riley v. State, 819 N.W.2d 162 (Minn. 2012) (clarifying elements required for newly discovered evidence exception)
Gassler v. State, 787 N.W.2d 575 (Minn. 2010) (explaining interests-of-justice exception factors)
Barrow v. State, 862 N.W.2d 686 (Minn. 2015) (plea validity requires accuracy, voluntariness, intelligence)
Lothenbach v. State, 296 N.W.2d 854 (Minn. 1980) (guilty plea waives most pre-plea constitutional claims)