People v. Matthews
2016 IL 118114
| Ill. | 2017Background
- Jerrell Matthews, a prisoner convicted of murder, mailed a section 2-1401 petition to the Cook County clerk and State’s Attorney on March 25, 2012, with a proof/certificate stating service by first-class prison mail.
- The clerk received and docketed the petition in April; the circuit court dismissed it sua sponte on May 24, 2012 as untimely and meritless.
- Matthews argued on appeal dismissal was premature because he did not effect service by certified/registered mail as required by Supreme Court Rule 105, so the State’s 30-day response period never began.
- The appellate court vacated the dismissal, concluding less than 30 days had elapsed after the State received actual notice; the State appealed to the Illinois Supreme Court.
- The Supreme Court considered whether Matthews could challenge the dismissal based on his own failure to comply with Rule 105 and whether he had standing to assert lack of personal jurisdiction over the State.
- The Court reversed the appellate court and affirmed the circuit court, holding Matthews was estopped from attacking service and lacked standing to challenge personal jurisdiction on behalf of the State; the petition was dismissed with prejudice.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Matthews) | Held |
|---|---|---|---|
| Whether Matthews may challenge dismissal based on his own failure to serve the State per Rule 105 | Matthews should be estopped; court may enforce Rule 105 strictly (People opposed reversal) | Matthews: dismissal was premature because service was improper (no certified/registered mail); 30-day response never began | Matthews is estopped/invited-error prevents relief; cannot complain of error he caused; dismissal affirmed |
| Whether Matthews has standing to challenge lack of personal jurisdiction over the State | Only the party owed service may object; Matthews cannot assert lack of jurisdiction on State’s behalf | Matthews: judgment void for lack of personal jurisdiction because State was not properly served | Matthews lacks standing; objections to personal jurisdiction may be waived by the party owed service; dismissal valid |
| Whether the circuit court could sua sponte dismiss before State’s response period expired | Court may dismiss if respondent had notice/waived service or otherwise appeared | Matthews: dismissal was premature because 30 days had not run after proper service | Court did not reach sufficiency of service; ruled Matthews estopped and lacked standing, so dismissal not invalidated |
Key Cases Cited
- People v. Laugharn, 233 Ill.2d 318 (trial court cannot sua sponte dismiss a section 2-1401 petition before the 30-day response period expires)
- People v. Vincent, 226 Ill.2d 1 (failure to answer within Rule 105 period waives objections to petition sufficiency)
- People v. Carter, 2015 IL 117709 (review standards; petitioner bears record burden on service issues)
- In re M.W., 232 Ill.2d 408 (objections to personal jurisdiction or service may be raised only by the party entitled to object)
- State Bank of Lake Zurich v. Thill, 113 Ill.2d 294 (personal jurisdiction requires service as directed unless waived)
- People v. Villarreal, 198 Ill.2d 209 (invited error/estoppel doctrine bars a party from challenging a result procured by their own tactic)
- People v. Harvey, 211 Ill.2d 368 (invited error and estoppel principles preclude appellate relief for errors the party invited)