Justia Alaska Supreme Court Opinion Summaries

The case involves a dispute over the control of a nonprofit corporation, which was dissolved by the State due to the executive director’s failure to pay taxes and fees and renew corporate registration. Despite the dissolution, the directors and members continued the corporation’s activities, unaware of the loss of corporate status. When the issue was discovered, some individuals filed paperwork to incorporate a new entity with the same name, offices, and bank account. A national affiliate proposed elections to resolve the leadership, but the new incorporators denied affiliation with the old corporation. Elections were held, and new directors were chosen, leading to litigation over who had authority to act on behalf of the new corporation.The Superior Court of Alaska, Third Judicial District, Anchorage, ruled that the new corporation was essentially the same entity as the old one, with the same members. The court concluded that the disputed election was valid and that the newly elected individuals had authority to act on behalf of the corporation. The court ousted the individuals who had filed the incorporation paperwork and awarded attorney’s fees to the prevailing parties but exempted individual litigants from liability for these fees.The Alaska Supreme Court largely affirmed the Superior Court’s rulings but vacated and remanded the dismissal of one third-party claim for a more detailed explanation. The court also vacated and remanded the Superior Court’s decision to excuse individual litigants from liability for attorney’s fees, finding the reason for this ruling invalid. The main holding was that the new corporation was the same entity as the old one, and the election of new directors was valid, giving them authority to act on behalf of the corporation. View "Aiken v. Alaska Addiction Professionals Association" on Justia Law

The case involves divorcing parents who had entered into a custody settlement agreement for their child, which included a provision for the child to move to New Jersey in 2022. The father later sought to modify this agreement, arguing that the child's emotional and behavioral health had deteriorated and that moving out of state would negatively impact the child's progress in therapy and school. The superior court found a substantial change in circumstances and awarded primary physical custody to the father, deciding that the child's best interests favored staying in Alaska.The superior court initially approved the custody settlement agreement but withheld judgment on the relocation provision. After further briefing, the court ruled that the relocation provision was enforceable but noted that the father could challenge it by demonstrating a substantial change in circumstances. The father filed a motion to modify custody, and after a trial, the superior court found that the child's emotional and behavioral issues had significantly worsened since the original agreement, constituting a substantial change in circumstances. The court concluded that the child's best interests required staying in Alaska with the father.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court's decision. The court found no clear error or abuse of discretion in the superior court's best interests analysis, which favored the father on several factors, including his capability and desire to meet the child's needs, the stability and continuity of the child's environment, and the willingness to facilitate a relationship with the other parent. The court also found that any error in admitting the parenting coordinator's reports was harmless, as the reports were largely cumulative of other evidence. The Supreme Court upheld the superior court's custody modification order, allowing the child to remain in Alaska with the father. View "J. M. v. S. C." on Justia Law

In July 2019, Tyler Blue, an inmate at Spring Creek Correctional Center, assaulted fellow inmate Patrick Torrence, causing abrasions, bruising, a mild concussion, and aggravation of a preexisting hip injury. Blue was criminally charged and pleaded guilty to assault in the fourth degree. In May 2022, Torrence filed a civil complaint against Blue, seeking damages for the injuries he sustained from the assault. Torrence's complaint referenced criminal statutes and sought restitution and compensation under various Alaska Statutes.The Superior Court of the State of Alaska, Third Judicial District, Seward, dismissed Torrence's complaint for failure to state a claim. The court concluded that the criminal statutes cited by Torrence did not support a private cause of action. Blue had argued that he could not be subjected to double jeopardy and that the court had already rendered judgment against him in the criminal case, including restitution. Torrence opposed the motion, asserting that the damages ordered in the criminal case were paid to the government, not to him, and that he had not been compensated for his injuries.The Supreme Court of the State of Alaska reviewed the case and concluded that Torrence's complaint, despite its reliance on criminal statutes, stated a claim for civil battery. The court held that the Superior Court erred in dismissing the complaint because Torrence had alleged facts consistent with a civil tort claim for battery. The court noted that the criminal conviction for assault did not preclude Torrence's civil suit for damages and that double jeopardy did not apply to civil claims. The Supreme Court reversed the Superior Court's dismissal and remanded the case for further proceedings, including providing procedural guidance to the self-represented litigants. View "Torrence v. Blue" on Justia Law

K.B., a patient at the Alaska Psychiatric Institute (API), has been under successive involuntary commitment orders since 2019 due to his diagnoses of schizoaffective disorder, antisocial personality disorder, and traumatic brain injury. His condition has led to violent outbursts and delusional behavior, resulting in his banishment from local shelters and hotels. In September 2022, Dr. Anthony Blanford, K.B.'s attending psychiatrist, filed another 180-day commitment petition. During the proceedings, K.B. expressed dissatisfaction with his appointed attorney, particularly over whether his trial would be by jury or bench.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, initially set the trial for late September. K.B.'s attorney informed the court that K.B. had requested a jury trial. However, on the first day of jury selection, K.B. indicated he preferred a bench trial. The court allowed defense counsel to consult with K.B., who confirmed his preference for a bench trial. The next day, K.B.'s attorney reported that K.B. had fired him for not listening and reiterated his preference for a bench trial. After further consultation, the attorney confirmed K.B.'s preference for a bench trial, and the court proceeded accordingly, ultimately granting the 180-day commitment petition.The Supreme Court of the State of Alaska reviewed the case. K.B. argued that the superior court erred by not conducting a representation hearing or inquiring further into his dissatisfaction with his attorney. The Supreme Court held that the superior court was not required to delve further into the attorney-client relationship. The court found that the circumstances, viewed objectively, did not indicate a breakdown in communication or decision-making capability between K.B. and his attorney. Therefore, the superior court's order granting the 180-day commitment was affirmed. View "In re Hospitalization of K.B." on Justia Law

A mother sought to modify visitation between her child and the child’s father due to allegations of domestic violence between the father and his new romantic partner. On the day of the hearing, the father’s attorney withdrew, and a new attorney took over. The court allowed the substitution but denied the father’s request for a continuance. The hearing proceeded and continued six days later. The court found the father had committed five acts of domestic violence and was not engaged in a previously ordered domestic violence intervention program. Initially, the court declined to modify visitation but later temporarily suspended the father’s visitation pending his engagement with the intervention program.The Superior Court of Alaska, First Judicial District, Sitka, initially found both parents had a history of domestic violence but awarded the mother sole legal and primary physical custody. The father was granted supervised visitation, contingent on completing a domestic violence intervention program. The mother later moved to suspend the father’s visitation, citing new acts of domestic violence and his disengagement from the intervention program. The hearing was delayed due to the father’s noncompliance with discovery, and his attorney’s conflict of interest led to a last-minute substitution of counsel.The Supreme Court of the State of Alaska reviewed the case. It affirmed the lower court’s decisions, finding no clear error or abuse of discretion. The court held that the denial of the continuance was justified given the previous delays and the new attorney’s familiarity with related proceedings. The findings of domestic violence were supported by credible testimony, and the temporary suspension of visitation was warranted due to the father’s continued violent behavior and failure to engage in the intervention program. The court emphasized the best interests of the child and provided clear steps for the father to resume visitation. View "Adam F. v. Caitlin B." on Justia Law

This case involves a dispute over a small triangular portion of land in south Anchorage, Alaska, between two neighbors, Janice Park and the Browns. The land in question was enclosed by a fence that had been in place since at least 1991, but a 2016 survey revealed that the fence veered slightly into the Browns' property. The Browns sued Park for trespass and to quiet title, while Park claimed adverse possession.The Superior Court of the State of Alaska ruled in favor of the Browns, concluding that Park failed to establish the required elements of adverse possession. The court found that Park's possession of the disputed area was open, notorious, exclusive, and hostile, but she did not exercise continuous possession of the area for the required ten-year statutory period.Park appealed to the Supreme Court of the State of Alaska, arguing that the lower court misapplied the law and displayed bias against her. The Supreme Court agreed that the lower court erred in rejecting Park's claim of adverse possession. The court found that Park had established continuous and uninterrupted possession of the disputed area for the ten-year statutory period between 2005 and 2015, satisfying the continuous-possession requirement under the doctrine of tacking. The court also held that Park presented clear and convincing evidence sufficient to satisfy the other elements of adverse possession. However, the court found insufficient evidence to support Park's claim of judicial bias. The Supreme Court reversed the judgment and remanded the case for entry of judgment in favor of Park. View "Park v. Brown" on Justia Law

Seth Lookhart, a dentist, was convicted of numerous crimes related to a fraudulent scheme that endangered his patients' health and safety. The scheme involved unnecessary sedation of patients to fraudulently bill Alaska’s Medicaid program, overcharging it by more than $1.6 million. Lookhart also stole $412,500 from a business partner. His reckless sedation practices nearly resulted in the loss of two patients' lives. He was arrested in April 2017 and convicted on 46 charges in January 2020, leading to a sentence of 20 years in prison with eight years suspended.Following Lookhart's convictions, the Division of Corporations, Business and Professional Licensing sought to revoke his dental license. Lookhart agreed to the facts of the accusation but argued that revocation was not an appropriate sanction. The administrative law judge (ALJ) disagreed, stating that Lookhart's misconduct was more severe than any prior case and that revocation was the clear and obvious sanction. The Board of Dental Examiners adopted the ALJ's decision.Lookhart appealed to the superior court, arguing that the Board's decision was inconsistent with its prior decisions. The court disagreed, stating that the Board had wide discretion to determine appropriate sanctions and that no prior case was comparable to Lookhart's. The court affirmed the Board's decision. Lookhart then appealed to the Supreme Court of the State of Alaska.The Supreme Court affirmed the lower court's decision. It held that the Board of Dental Examiners did not abuse its discretion by revoking Lookhart's license. The court found that none of the Board's prior licensing cases involved misconduct of the scope and severity in this case, so there was no applicable precedent to limit the Board's exercise of its discretion. View "Lookhart v. State of Alaska, Board of Dental Examiners" on Justia Law

A teacher, who was involved in a car accident caused by a third party, sustained serious injuries. The teacher was covered under his employer’s self-insured healthcare plan, which stipulates that the employer has a right of reimbursement for medical expenses if a covered person receives a separate settlement. The employer paid for the teacher’s medical expenses and the teacher also received $500,000 in settlements from two separate insurers. The teacher requested that the employer waive its right to reimbursement twice, but the employer never agreed. Two years after the teacher notified the employer of his insurance settlements, the employer requested reimbursement and later sued him for breach of contract.The Superior Court of the State of Alaska granted summary judgment to the employer on the issue of whether the teacher breached the contract to reimburse the employer. The employer then moved for summary judgment on the amount of damages, providing an affidavit from its Plan Administrator and a claims ledger. The teacher opposed the motion, providing his own affidavit and a self-created spreadsheet in support of his argument that some of the medical costs paid by the employer were not associated with the accident. The court granted the employer’s motion for summary judgment on contract damages.The Supreme Court of the State of Alaska affirmed the lower court’s summary judgment order regarding breach of contract, but held that the teacher raised a genuine dispute of material fact regarding damages. Therefore, the Supreme Court reversed and remanded the lower court’s summary judgment order regarding contract damages. View "Fischer v. Kenai Peninsula Borough School District" on Justia Law

The case revolves around a dispute between a condominium association and the owner of two commercial units over parking and storage space. The commercial owner, Cooper Leasing, claimed ownership of certain parking spots and a storage area within the condominium property. The condominium association, Woronzof Condominium Association, disputed this claim.The Superior Court of the State of Alaska ruled that the condominium’s governing documents did not grant the commercial owner ownership of any parking spots. However, it ruled in favor of the commercial owner on the storage dispute, finding that the association had agreed decades earlier to swap the condominium’s general storage area with the area designated for commercial storage.Cooper Leasing appealed the ruling on parking, and the association cross-appealed the ruling on storage. The Supreme Court of the State of Alaska affirmed the ruling on parking, but vacated the ruling on storage. The court held that the terms of the declaration, in light of relevant extrinsic evidence, were ambiguous as to whether it was intended to give the commercial units the exclusive rights to use certain parking spots. The court also held that owners of condominiums have a property interest in both their own units and in the common areas of the condominium. Because a special test for when the doctrine of quasi-estoppel can be used to defeat record title to real property was not applied to the commercial owner’s quasi-estoppel claim to the storage space, the court vacated and remanded for further proceedings. View "Cooper Leasing, LLC v. The Woronzof Condominium Association" on Justia Law

The case involves the Alaska Trappers Association and the National Trappers Association (collectively, the Trappers) who challenged a city ordinance enacted by the City of Valdez. The ordinance regulated animal trapping within the city limits, barring trapping in certain areas for the purpose of protecting public safety and domesticated animals. The Trappers argued that the ordinance was invalid and unconstitutional, asserting that it was preempted by state law and violated the Alaska Constitution.The Superior Court of the State of Alaska, Third Judicial District, Valdez, granted summary judgment in favor of the City of Valdez. The court concluded that the legislature's delegation of authority to the Board of Game was limited and did not grant the Board exclusive control of trapping. The court also determined that the ordinance did not directly contradict state regulations.Upon appeal, the Supreme Court of the State of Alaska affirmed the lower court's decision. The Supreme Court held that the ordinance was not prohibited by the Alaska Constitution or the legislature’s delegation of authority over fish and game to the Board. The court concluded that the ordinance was not impliedly prohibited by state law, as it was enacted pursuant to Valdez's authority to regulate land use and public safety, and was not substantially irreconcilable with the State's authority to regulate the conservation, development, or utilization of game. View "Alaska Trappers Association, Inc. v. City of Valdez" on Justia Law