Justia Alaska Supreme Court Opinion Summaries

An individual was admitted to a hospital after a medical emergency and, following treatment, was held for mental health concerns. Hospital staff petitioned for his transport to a designated evaluation facility, citing symptoms of serious mental illness and inability to make rational decisions. Although the court ordered immediate transport for evaluation, the individual remained at the hospital for two weeks due to lack of capacity at evaluation facilities. After a hearing, the court found this prolonged detention violated his substantive due process rights and ordered his release. However, the individual remained at the hospital for three more days, after which the hospital filed a second petition based on new information. The court granted this petition, and the individual was detained for an additional nine days before being transported for evaluation.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, first dismissed the initial petition and ordered the individual's release, finding the extended detention unconstitutional. Upon the hospital’s second petition, the court approved another period of detention, reasoning that new information justified the renewed hold and that delays were due to facility refusals and capacity issues. After the individual was finally transported and evaluated, the evaluation facility petitioned for a 30-day commitment, which the superior court granted following a hearing.The Supreme Court of the State of Alaska reviewed the case. It held that the second period of detention, especially when considered alongside the prior extended detention, violated the individual’s substantive due process rights because the nature and duration of the detention were not reasonably related to the limited purpose of facilitating immediate transportation for evaluation. The court also found that the State failed to prove by clear and convincing evidence that commitment was the least restrictive alternative. Accordingly, the Supreme Court vacated both the superior court’s order upholding the second detention and the 30-day commitment order. View "In the Matter of the Necessity for the Hospitalization of: Tavis J." on Justia Law

A longtime Alaska resident with extensive experience in personal-use and commercial fishing brought suit against the State of Alaska, alleging that the State’s management of chinook and chum salmon populations in the Yukon and Kuskokwim Rivers violated the sustained yield principle mandated by the Alaska Constitution. The plaintiff claimed that the significant decline in these salmon populations since statehood was evidence of unconstitutional management. He did not challenge any specific policy, regulation, or action, but instead sought a declaration that the State’s management had been unconstitutional for decades and requested injunctive relief to compel the State to fulfill its sustained yield obligations.The Superior Court for the Fourth Judicial District, Bethel, granted the State’s motion to dismiss for failure to state a claim. The court found that the claims presented nonjusticiable political questions reserved for the legislative branch, that the plaintiff failed to allege a concrete injury or identify specific State actions causing harm, and that deference to agency expertise was warranted in the absence of a challenge to a particular policy or action.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s dismissal. The Supreme Court held that the claims for injunctive relief were nonjusticiable because they would require the judiciary to make initial fisheries policy determinations, a function constitutionally committed to the legislative and executive branches. The Court further held that the claim for declaratory relief was not justiciable because it would not clarify or settle the legal relations between the parties, as it did not identify specific actions or policies to be addressed. The Court concluded that, absent a challenge to a particular State action or policy, the claims did not present an actual controversy suitable for judicial resolution. View "Forrer v. State of Alaska" on Justia Law

Several months before an election, complaints were filed with the Alaska Public Offices Commission alleging that two political groups, A Stronger Alaska and the Republican Governors Association, had violated Alaska’s campaign finance laws by coordinating with a gubernatorial campaign and failing to comply with disclosure requirements. The Commission initiated expedited proceedings, held hearings where officials from the groups testified, and then chose not to make a final determination on the alleged violations. Instead, the Commission remanded the matters to its staff for further investigation on a regular, non-expedited basis. The Commission’s staff subsequently issued administrative subpoenas seeking documents and communications from the groups, but the groups refused to comply.The Commission sought judicial enforcement of its subpoenas in the Superior Court for the State of Alaska, Third Judicial District. The groups opposed enforcement, arguing that the subpoenas were unnecessary because the Commission already had relevant testimony, that further investigation was barred by res judicata, and that the process violated their due process rights. They also challenged the constitutionality of the statutory scheme authorizing the expedited process. The superior court rejected all of these arguments, granted summary judgment in favor of the Commission, and ordered enforcement of the subpoenas.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s decision. The court held that the subpoenas were not unreasonable or oppressive simply because prior testimony had been given, as documentary evidence could still be relevant. The court also held that res judicata did not apply because the Commission had not issued a final decision on the merits, and that the process did not violate substantive due process or result in an absurd or unconstitutional statutory scheme. The court affirmed the order granting summary judgment to the Commission. View "Republican Governors Association v. Hebdon" on Justia Law

A fuel distribution company sought to acquire a competitor in Western Alaska, prompting the State to sue for anticompetitive conduct under Alaska’s consumer protection laws. To resolve the dispute, the State and the company negotiated a consent decree requiring the company to divest a portion of its fuel storage capacity in Bethel to another distributor, Delta Western, before completing the acquisition. The consent decree specified that it would expire in 30 years or could be dissolved by court order for good cause. Delta Western was not a party to the consent decree, but entered into a separate fuel storage contract with the acquiring company as required by the decree. The contract’s term extended beyond the initial five years at Delta Western’s option.Years later, the Superior Court for the State of Alaska, Second Judicial District, Nome, dissolved the consent decree at the acquiring company’s request. The company then notified Delta Western that it considered the fuel storage contract terminated as a result. Delta Western filed a breach of contract action in Anchorage Superior Court, seeking to enforce the contract and arguing that its terms were independent of the consent decree. The contract case was transferred to Nome Superior Court, which issued a preliminary ruling that the contract remained valid despite the dissolution of the consent decree. The court also vacated its initial order dissolving the consent decree to allow Delta Western to intervene and present its position.The Supreme Court of the State of Alaska reviewed whether dissolution of the consent decree automatically terminated the fuel storage contract and whether the superior court abused its discretion by permitting Delta Western to intervene. The court held that dissolution of the consent decree did not automatically void the contract between the parties, and that the superior court did not abuse its discretion in allowing Delta Western to intervene. The Supreme Court affirmed the superior court’s decisions and lifted the stay on the contract case. View "Crowley Marine Services, Inc. v. State of Alaska" on Justia Law

The case concerns the repeal of a regulation that had banned the use of personal watercraft, commonly known as jet skis, in two designated Critical Habitat Areas (CHAs) in Alaska: Kachemak Bay and Fox River Flats. The Alaska Department of Fish and Game (ADF&G) Commissioner originally enacted the ban in 2001, citing concerns about the potential impact of jet skis on fish, wildlife, and their habitats. In 2021, after a review process that included public comment and consideration of scientific literature, the Commissioner repealed the ban, reasoning that technological improvements had reduced the environmental impact of jet skis and that existing studies did not conclusively demonstrate significant harm in these specific northern marine environments.Conservation groups challenged the repeal in the Superior Court for the Third Judicial District, Anchorage, arguing that the Commissioner lacked statutory authority to repeal the regulation and that the repeal was inconsistent with the statutory purpose of protecting critical habitat. The superior court granted summary judgment to the conservation groups, finding that the Commissioner did not have the authority to repeal the ban and that the repeal conflicted with the purpose of the CHA statutes. The court reinstated the ban and awarded attorney’s fees to the conservation groups.On appeal, the Supreme Court of the State of Alaska reviewed the superior court’s decision de novo. The Supreme Court held that the Commissioner had both implied statutory authority and delegated authority from the Boards of Fisheries and Game to enact and repeal regulations governing uses within CHAs. The Court further found that the repeal was consistent with the statutory purpose of the CHA statutes, was reasonable, and was not arbitrary or in conflict with other laws. The Supreme Court reversed the superior court’s decision, directed entry of summary judgment in favor of the State, and remanded for further proceedings regarding prevailing party status and attorney’s fees. View "Department of Fish & Game v. Cook Inletkeeper" on Justia Law

After the birth of a child who qualified as an Indian child under the Indian Child Welfare Act (ICWA), the Office of Children’s Services (OCS) in Alaska took emergency custody due to the mother’s substance use during pregnancy. Initially, no relatives were available for placement, so the child was placed with a non-relative foster parent. Nearly two and a half years later, the mother requested that the child be placed with his great-grandmother. OCS denied this request, citing unsafe conditions in the great-grandmother’s home, including excessive clutter that posed safety risks. The great-grandmother made some improvements but did not sufficiently address the concerns. OCS also expressed doubts about her judgment and ability to protect the child, referencing past incidents involving other family members.The Superior Court of the State of Alaska, Fourth Judicial District, held a placement review hearing after the great-grandmother requested judicial review of OCS’s denial. The court found by clear and convincing evidence that OCS did not abuse its discretion in denying the placement, determining that the great-grandmother’s home remained unsuitable and that her past actions raised concerns about her ability to prioritize the child’s needs. The court also concluded that OCS was not required to provide the great-grandmother with reasonable efforts to make her home suitable, as she was not the child’s parent or guardian.On appeal, the Supreme Court of the State of Alaska considered whether ICWA required OCS to demonstrate “active efforts” to assist the great-grandmother in overcoming obstacles to placement. The court held that ICWA’s active efforts requirement applies to preserving or reunifying the family unit with a parent or Indian custodian, not to extended family members seeking placement. Therefore, OCS was not required to provide active efforts to the great-grandmother in this context. The Supreme Court affirmed the superior court’s decision upholding OCS’s denial of placement. View "Betsy F. v. State" on Justia Law

A nurse employed at a hospital in Alaska claimed that he contracted a persistent Clostridiodes difficile (C. diff) infection as a result of workplace exposure in September 2018. He had a preexisting gastrointestinal condition but experienced worsening symptoms after caring for a patient with C. diff. After returning to Arkansas, he continued to suffer from the infection and sought workers’ compensation benefits, asserting that his illness was work-related. The hospital disputed the claim, arguing that the infection was not caused by workplace exposure.The Alaska Workers’ Compensation Board initially found the nurse credible, determined that he contracted C. diff at work, and awarded him temporary total disability and medical benefits. The Board also ruled that the hospital had waived its right to cross-examine the authors of certain medical reports submitted by the nurse, because the hospital’s requests for cross-examination were not filed within the time limits set by 8 AAC 45.052. The Alaska Workers’ Compensation Appeals Commission reviewed the case and concluded that the Board erred in applying 8 AAC 45.052, reasoning that the documents in question were not “medical reports” as defined by the regulation. The Commission held that the general evidentiary rule, 8 AAC 45.120, applied instead, and that the hospital’s cross-examination requests were timely. The Commission remanded the case to the Board to allow cross-examination of the doctors.On remand, a new Board panel held a de novo hearing, reversed most of the prior factual findings, and denied the nurse’s claim for benefits. The Commission affirmed this denial. The Supreme Court of the State of Alaska held that the Commission erred in its interpretation of “medical reports” under 8 AAC 45.052, finding the Board’s broader interpretation reasonable and consistent with longstanding practice. The Supreme Court reversed the Commission’s remand order, vacated subsequent decisions, and remanded for reinstatement of the original compensation award. View "Woodell v. Alaska Regional Hospital" on Justia Law

A couple married in 2002 after signing a prenuptial agreement that largely kept their finances separate, with the husband retaining significant assets and the wife having much less. The agreement, signed ten days before the wedding, stated that each party’s property and earnings would remain separate, and it limited the wife’s ability to seek attorney’s fees, spousal support, or an unequal division of marital property in the event of divorce. During the marriage, the husband committed multiple acts of domestic violence against the wife, which ultimately led to their separation and the wife filing for divorce after nearly eighteen years.The Alaska Superior Court, Third Judicial District, Anchorage, held a divorce trial and found the wife’s testimony more credible, determining that the husband had committed four crimes of domestic violence. The court found the prenuptial agreement was voluntarily signed and not unconscionable at the time of execution, but concluded that changed circumstances—specifically, the husband’s domestic violence—made it unfair to enforce provisions barring the wife from seeking attorney’s fees, spousal support, or an unequal division of the marital estate. The court awarded the wife 75% of the marital estate, but did not include proceeds from a California timeshare in the division and counted $80,000 the wife withdrew at separation against her share. The court also based child support on the husband’s claimed tax rate without supporting evidence.On appeal, the Supreme Court of the State of Alaska affirmed in part and reversed in part. It held that the prenuptial agreement was not unconscionable and was voluntarily signed, but that the superior court could strike certain terms due to changed circumstances, such as domestic violence, while enforcing others. The Supreme Court remanded for further explanation regarding which terms should be enforced, for inclusion of the California timeshare in the property division, for reconsideration of the $80,000 withdrawal, and for recalculation of child support based on proper tax evidence. View "Kilkenny v. Kilkenny" on Justia Law

A business was investigated by the Consumer Protection Unit (CPU) of the Alaska Attorney General’s Office after the CPU received an anonymous letter alleging that the business, a local car dealership, was charging documentation fees on top of advertised prices, potentially violating Alaska law. The letter included an email exchange confirming the practice. Following approval from the Department of Law, the CPU monitored the business’s website and conducted an undercover visit, during which employees confirmed the additional fees. In December, the CPU issued a subpoena requesting documents related to vehicle sales, including contracts and advertisements, to further its investigation.After the business missed the deadline to produce documents, it petitioned the Superior Court for the State of Alaska, Third Judicial District, Anchorage, to quash the subpoena. The business argued that the CPU lacked “cause to believe” a violation had occurred, as required by statute, and challenged the reliability of the anonymous complaint and the legitimacy of the undercover investigation. The CPU responded that the subpoena was an administrative subpoena, subject to a low threshold for issuance, and that the letter and email provided a sufficient basis for investigation.The Superior Court denied the petition to quash, finding that the subpoena was authorized under AS 45.50.495(b), was part of a good-faith investigation, and adequately specified the documents to be produced. The court held that the “cause to believe” standard did not apply to the subpoena power in subsection (b), but that even if it did, the evidence met the low bar required. The business appealed.The Supreme Court of the State of Alaska affirmed the superior court’s order, holding that the CPU had sufficient basis to issue the subpoena under AS 45.50.495(b), regardless of whether the “cause to believe” standard applied. The court found no abuse of discretion in the superior court’s decision. View "Business Doe, LLC v. State of Alaska" on Justia Law

A married couple separated after more than twenty years together and reached a settlement agreement to divide the marital portion of the husband’s Alaska Railroad Corporation pension plan equally, including a 50% survivor benefit for the wife. However, the pension plan’s terms did not allow for the precise division the parties intended. The plan only permitted three options for survivor benefits: no survivor, treating the wife as the surviving spouse (which would give her more than her marital share), or a conditional benefit that could end if the husband remarried and predeceased the wife. The husband proposed selecting the third option and, if he remarried, purchasing life insurance to protect the wife’s interest. The wife objected, expressing concern about relying on the husband to maintain life insurance and arguing for the option that would make her the sole survivor beneficiary.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, selected the third option, allowing the husband to name a future spouse as a joint survivor beneficiary, but did not require him to purchase life insurance. The court reasoned that this option most fairly allocated the risks and reflected the parties’ agreement to divide only the marital portion of the plan. The court did not address or incorporate the husband’s offer to purchase life insurance in its order.On appeal, the Supreme Court of the State of Alaska reviewed whether the superior court abused its discretion by not requiring life insurance or otherwise protecting the wife’s survivor benefit interest. The Supreme Court held that the superior court erred by failing to explain why it did not require the husband to purchase life insurance or otherwise ensure the wife’s interest was protected. The Supreme Court vacated the superior court’s order and remanded the case for further proceedings, instructing the lower court to reconsider the life insurance offer and explain its decision. View "Sandvik v. Frazier" on Justia Law