Justia Alaska Supreme Court Opinion Summaries

Two nieces, acting as co-guardians for their elderly uncle, sued their uncle's former caregiver for misuse and misappropriation of his assets; the caregiver counterclaimed for compensation for services rendered. After a bench trial, the superior court: (1) determined the caregiver had committed fraud and breached fiduciary duties; (2) awarded damages against the caregiver for her misuse and misappropriation of the uncle’s assets; (3) awarded the caregiver some compensation for her services in quantum meruit; and (4) ordered the caregiver's name removed from title to the uncle's house. The caregiver appealed. Because the superior court's findings of fact were well supported, and its application of equitable considerations was well within its discretion, the Supreme Court affirmed its decision. View "Shears v. Myers" on Justia Law

A State of Alaska employee was discharged. With union representation, the employee unsuccessfully challenged his termination in grievance proceedings. When he later filed suit for wrongful termination, the State subpoenaed the union representative to appear for a deposition with the union's grievance file. The superior court denied the employee's privilege-based request for a protective order. The Supreme Court granted the employee's petition for review to consider whether a union-relations privilege exists in Alaska. The Court concluded the privilege exists by implication of Alaska statutes, and therefore reversed the superior court's ruling and remanded the case for application of the privilege to the discovery dispute. View "Peterson v. Alaska" on Justia Law

Holiday Alaska, Inc. (Holiday) sells tobacco at over 25 stores in Alaska, and each store holds a tobacco license endorsement from the State. The State sought to suspend five different Holiday stores' tobacco license endorsements following five separate incidents of Holiday employees' illegal tobacco sales to minors. Each case resulted in conviction: One employee was found guilty by default judgment, three pled guilty, and one was found guilty at trial. Holiday requested a hearing before the Office of Administrative Hearings in each case. An Administrative Law Judge (ALJ) held two hearings. The ALJ first considered the allegations against Holiday resulting from four of the convictions and issued a consolidated decision; the ALJ later considered the allegations against Holiday resulting from one additional employee's conviction and issued a separate decision. Throughout the proceedings Holiday asserted various constitutional challenges, which the ALJ denied because he could not "rule on a constitutional challenge that seeks to nullify the statute." However, the ALJ allowed Holiday to present evidence relevant to its constitutional challenges to construct a factual record for appeal. Holiday appealed the ALJ decision to the superior court, which rejected Holiday's constitutional arguments. Holiday presented one challenge on appeal: whether AS 43.70.075 violated its due process rights. In "Godfrey v. State of Alaska, Department of Community & Economic Development," the Supreme Court upheld a version of AS 43.70.075, the tobacco endorsement statute, against several due process challenges. While those challenges were pending the legislature amended the statute to address due process concerns. In this opinion, the Court considered due process challenges to the amended statute, and affirmed the superior court's conclusion that the amended statute provides due process. View "Holiday Alaska, Inc. v. Alaska" on Justia Law

After the State of Alaska issued a plan for summer-use rules at Willow Lake, at which the State operates as a float plane facility, a non-profit corporation brought suit against the State and a float plane operator, alleging: (1) the State's plan was unconstitutional, improperly issued, and preempted by federal navigable water and aviation laws; and (2) the float plane operations created a public nuisance. The superior court granted summary judgment on the basis that the corporation lacked standing to bring its claims, but further concluded that the use plan was properly issued and not preempted by federal navigable water law. Upon review, the Supreme Court affirmed the superior court’s ruling that the use plan was not a regulation required to be promulgated under formal administrative procedures. But because the corporation had associational standing and there was insufficient development of the record for the preemption ruling, the Court reversed and remanded the case for further proceedings. View "Friends of Willow Lake, Inc. v. Alaska" on Justia Law

A healthcare worker was sprayed in the eye with fluids from an HIV-positive patient. She received preventive treatment and counseling. Her employer initially paid workers' compensation benefits; it later filed a controversion based on its doctor's opinion that the employee was able to return to work. The employee asked for more benefits, but the Alaska Workers' Compensation Board denied her claim. The employee appealed, but the Alaska Workers' Compensation Appeals Commission affirmed the Board's decision. Because the Supreme Court agreed with the Commission that substantial evidence supported the Board's decision, the Court affirmed the Commission's decision. View "Runstrom v. Alaska Native Medical Center" on Justia Law

The Office of Rate Review, a division of the State Department of Health and Social Services (DHSS), set a Medicaid payment rate for North Star Hospital based on a 2005 home office cost report that did not reflect a substantial increase in costs incurred by North Star in 2006. While making its determination, the Office of Rate Review had access to an unaudited version of a 2006 home office cost report that reflected these increased costs. The Office of Rate Review refused to grant North Star's request for an interim rate pending the audit of the 2006 report or to reconsider the rate once it received the audited 2006 report. In response, North Star administratively challenged the Office of Rate Review's rate determination. The DHSS Commissioner concluded that the Office of Rate Review's refusal to consider data from the unaudited 2006 report was proper and that the Office of Rate Review was not required to grant North Star a temporary rate preceding completion of the audit of the 2006 report. The Commissioner also concluded that DHSS did not have jurisdiction to determine whether 7 Alaska Administrative Code (AAC) 150.170(b)(12) was in conflict with AS 47.07.070, which requires that the rate be based upon reasonable costs. North Star appealed the decision to the superior court and the superior court reversed, concluding that because the audited 2006 home office cost statement was overdue at no fault of North Star, it was error for the Office of Rate Review to refuse to grant North Star's request for a temporary rate in order to consider the audited version of the 2006 report. Upon review, the Supreme Court affirmed the superior court's decision. View "Alaska v. North Star Hospital" on Justia Law

A man was arrested for misdemeanor crimes after an altercation arising from a business dispute. He brought civil claims against a police officer and the officer's municipal employer based on the arrest. The superior court granted a motion for summary judgment and dismissed all claims against them. Upon review, the Supreme Court affirmed the superior court's decision because: (1) the police officer had probable cause to make a felony arrest, and, therefore, any perceived deficiencies in the misdemeanor arrest process are irrelevant; and (2) no municipal policy deprived the arrestee of property, and, therefore, the municipality did not violate the arrestee's constitutional rights. View "Yi v. Yang" on Justia Law

The passenger of a car was injured in a two-car accident. The passenger brought suit against the other car's driver; the passenger's requested recovery included her insurer's subrogation claim for medical expenses. The driver made an early offer of judgment, which the passenger rejected. The driver then paid the subrogation claim, thereby removing it from the passenger's expected recovery. The driver then made a second offer of judgment, which the passenger rejected, and the case proceeded to trial. After trial the jury awarded the passenger damages and both parties claimed prevailing party status; the driver sought attorney's fees under Alaska Civil Rule 68. The superior court ruled the first offer of judgment did not entitle the driver to Rule 68 fees, but the second offer did. Both parties appealed, arguing the superior court improperly considered the subrogation claim in its Rule 68 rulings. Upon review, the Supreme Court concluded the subrogation payment had to be taken into account when evaluating the first offer of judgment, but not the second. The Court therefore affirmed the superior court's rulings. View "Dearlove v. Campbell" on Justia Law

This appeal presented the question of whether the Alaska State Commission for Human Rights (the Commission) must interview one or more witnesses identified by a complainant before dismissing a complaint for lack of substantial evidence to support a discrimination claim. Upon review, the Supreme Court concluded that the statutory duty to impartially investigate implied that the Commission must make a reasonable effort to interview at least some of the witnesses identified by a complainant where it appears that they may have relevant information. The Court also concluded that this duty was not satisfied under the facts of this case because the Commission did not interview any of the witnesses identified by the complainant even though they potentially had relevant information. View "Toliver v. Alaska State Comm'n for Human Rights" on Justia Law

A worker suffered an above-the-knee amputation of his right leg in a work-related accident in 2003. The accident happened when he used his foot to push a bale of mulch that he was feeding into a machine; his leg was caught in the machine and later had to be amputated. He received workers’ compensation benefits for the injury and later sued the manufacturer and the owner of the machine under various tort theories. After trial a jury found that the manufacturer was not negligent and the product was not defective. It also found that the company that owned the machine at the time of the accident was negligent, but that its negligence was not a legal cause of the accident. After finding that the worker and his employer were negligent and that their negligence was a cause of the accident, the jury apportioned fault for the injury between them. Because the Supreme Court concluded that the superior court erroneously admitted evidence of the worker's receipt of workers' compensation and social security benefits and his past drug use, the Court reversed the trial court’s judgment and remanded the case for a new trial. View "Jones v. Bowie Industries, Inc." on Justia Law