Justia Alaska Supreme Court Opinion Summaries

In 2001, Union Oil Company of California entered into a contract to sell its oil to Tesoro Alaska Company. Under the contract the Tesoro took title at the North Slope, but agreed to use a pipeline company associated with Union to transport oil through the Trans-Alaska Pipeline. The price per barrel was calculated as the West Coast market price less marine transport and pipeline tariff. The contract made no mention of whether the pipeline tariff was tied to the ultimate destination of the oil. At the time, the interstate and intrastate pipeline tariffs were the same. Tesoro shipped the oil to an in-state refinery and paid the tariff to the pipeline company. Union subtracted the tariff amount from the market price of the oil less marine transport and sent invoices to the buyer. Meanwhile, Tesoro successfully challenged the intrastate tariff as unjust and unreasonable and the pipeline company issued a refund, including 10.5% interest. Union claimed that it was entitled to the tariff refund under the contract. The superior court, on motions for summary judgment, awarded the principal amount of the refund to Union and the interest to Tesoro. Both parties appealed. Upon review of the dispute, the Supreme Court held that the contract's pricing term was a netback price to the Los Angeles market referencing the interstate tariff. Accordingly, the Court reversed the superior court's grant of summary judgment to Union and remanded for entry of judgment in favor of Tesoro. View "Tesoro Alaska Company v. Union Oil Company of California" on Justia Law

In 2007, a shareholder of Calais Company, Inc., Deborah Kyzer Ivy, filed a complaint against Calais seeking involuntary corporate dissolution. In May 2009, Ivy and Calais reached a settlement agreement in which Calais agreed to purchase Ivy's shares at "fair value" as determined by a three-member panel of appraisers. The appraisers disagreed over the fair value of the company. Calais sought to enforce the Agreement in superior court, arguing the two majority appraisers had failed to comply with the appraisal procedure mandated by the Agreement and the Agreement's definition of "fair value." The superior court ultimately declined to rule on the issue, concluding that interpreting the term "fair value" was beyond its scope of authority under the terms of the Agreement. Consequently, the court ordered Calais to purchase Ivy's shares based on the majority appraisers' valuation. Calais appealed. Upon review of the matter, the Supreme Court reversed the superior court's final order and remanded for the court to remand to the appraisers with explicit instructions to calculate the "fair value" as defined by AS 10.06.630(a), as required by the Agreement. View "Calais Company, Inc. v. Kyzer Ivy" on Justia Law

The issue presented to the Supreme Court in this case involved a dispute over the disposition of a deceased Alaska attorney's interest in attorney's fees from his participation, through a joint venture, in the Exxon Valdez oil spill litigation. The attorney's sister, individually and on behalf of their mother's trust, asserted claims to the attorney's fees, and the attorney's estate opposed those claims. The parties settled the dispute by agreeing that the right to attorney's fees was an estate asset, and the settlement was approved by the Alaska superior court in the deceased attorney's probate proceedings. The attorney's fees were ultimately paid to the joint venture. Both the estate and the sister then sought the deceased attorney's interest in the joint venture's attorney's fees. The estate requested that the superior court enjoin the sister's claims as violations of the settlement agreement. Around this time, the joint venture deposited what it calculated as the deceased attorney's share of the joint venture's attorney's fees in a federal interpleader action in California. The superior court ruled that under the settlement agreement, as between the estate, the sister, and the mother's trust, the estate had the right to the deceased attorney's share of the attorney's fees held by the joint venture. The superior court therefore enjoined the sister from pursuing claims to the deceased attorney's share of the joint venture's attorney's fees. The superior court later modified the injunction to allow the sister's participation in the federal interpleader action. The sister appeals, arguing that the superior court exceeded its jurisdiction, issued its judgment without proper procedures, improperly interpreted the settlement agreement, prohibited her from pursuing contract claims against third parties, and entered a vague and ambiguous judgment. She also argues that the superior court's ruling was improperly expanded to allow her participation in the federal interpleader action. Because the Supreme Court concluded that the superior court acted within its jurisdiction, followed adequate procedures, did not prevent the sister from pursuing her individual contract claims against the joint venture, was not vague and ambiguous in its ruling, and did not expand the ruling's substance when modifying it, the Court affirmed the superior court's orders and judgment. View "Dimeff v. Estate of Robert Merle Cowan" on Justia Law

A medical service provider filed but failed to serve a complaint against a former patient and her insurer. The superior court dismissed the complaint without prejudice for lack of service. Nearly a year later, the medical service provider filed a second complaint against the same parties. The superior court granted summary judgment dismissing that complaint, ruling that the medical service provider's claims were barred by the statute of limitations and that Alaska's savings statute (AS 09.10.240) did not apply because of failure to provide timely notice of the initial complaint. The medical service provider appealed. Upon review, the Supreme Court concluded that AS 09.10.240 does not require timely notice of the initial complaint. Accordingly, the Court reversed the superior court's order granting summary judgment and remanded the case for further proceedings. View "American Marine Corporation v. Sholin" on Justia Law

In 2008 Robert Rude, then a sitting Cook Inlet Region, Inc. (CIRI) director, and three other candidates ran as an independent “New Alliance” slate for positions on the CIRI board of directors. Shortly before the election, CIRI filed suit, claiming that the New Alliance proxy materials contained materially misleading statements. Rude and his co-defendants counterclaimed, alleging that CIRI’s election procedures were unfairly tilted toward the interests of the current board and that the directors had improperly refused to disclose shareholder and corporate information to Rude and the other New Alliance candidates. The superior court granted summary judgment on all claims and counterclaims in favor of CIRI. As a result, the New Alliance proxies were voided, and Rude was not re-elected to the board. Rude appealed the rulings both on CIRI’s claims and his counterclaims. Although Rude’s claims were technically moot, the Supreme Court addressed them insofar as they potentially affected prevailing party status. Because no issue of material fact existed as to the claims at issue and because CIRI is entitled to judgment as a matter of law, the Supreme Court affirmed the superior court. In a separate appeal, Rude challenged four other rulings of the superior court: (1) the award of attorney’s fees to CIRI; (2) denial of his Rule 60(b) motion for relief from judgment; (3) the superior court’s exclusion of exhibits filed with that motion; and (4) dismissal of New Alliance as a party to this suit. Because the superior court did not abuse its discretion in any of these rulings, the Supreme Court affirmed the superior court in all respects. View "Rude v. Cook Inlet Region, Inc." on Justia Law

A bar served a man alcohol while he was visibly intoxicated, and the man murdered a woman later that evening. The lawyer representing the bar in the subsequent dram shop action did not attempt to add the murderer as a party for apportionment of fault. Following entry of a large judgment against the bar, the bar brought a legal malpractice suit against its attorney. The attorney moved to dismiss for failure to state a claim upon which relief could be granted, arguing that where case law is unsettled, as a matter of law an attorney cannot be held liable for an error in judgment. The superior court granted the motion and the bar appealed. "Because the existence of unsettled law does not excuse an attorney from fulfilling a duty of care," the Supreme Court reversed and remanded the case for further proceedings. View "L.D.G., Inc. v. Robinson" on Justia Law

Alyeska Pipeline Service Company (Alyeska), the agent for the owners of the Trans Alaska Pipeline System (TAPS), leases the TAPS right-of-way from the Alaska Department of Natural Resources (Department). Alyeska appealed the Department's 2002 appraisal of the TAPS lease price to Michael Menge, the Commissioner of the Department, and then to the superior court. Both affirmed the Department's appraisal. Alyeska appealed to the Supreme Court, arguing: (1) the Department misinterpreted AS 38.35.140(a); (2) the Department was required to adopt its interpretation of AS 38.35.140(a) as a regulation under the Administrative Procedure Act (APA); and (3) the appraisal improperly included submerged lands within the right-of-way when the Department failed to establish that the State holds title to those lands. Finding no misinterpretation, the Supreme Court affirmed. View "Alyeska Pipeline Service Co. v. Alaska" on Justia Law

Two mining companies entered a ten-year mining lease. The lessee was responsible for mining and prospecting claims owned by the lessor and its president. The companies entered a holdover tenancy after the expiration of the lease. During this time, an officer of the lessee company staked mining claims that overlapped with the claims his company had mined under the ten-year lease. In his own name, that officer filed location notices for the newly staked claims with the State Department of Natural Resources. The parties disagreed about who rightfully owned the claims staked during the holdover tenancy and broke off their lease agreement in October 2003. In 2007, the former lessor filed suit against the former lessee and its two officer-shareholders, seeking to quiet title to the disputed mining claims, to eject the former lessee and its officers from the claims, and to secure damages under several tort and contract causes of action. The former lessee denied various allegations, raised 13 affirmative defenses, and counterclaimed for the value of labor performed on the claims. Following a three-week trial, the superior court resolved the dispute in favor of the former lessor. The former lessee filed two appeals of post-trial orders, which we have consolidated for decision. Upon review of the matter, the Supreme Court affirmed the superior court on all but one issue: because specific findings were needed to pierce the corporate veil, the Court reversed the entry of judgment and the award attorney's fees against the wife of the officer of the lessee company and remanded for further proceedings. View "Gold Dust Mines, Inc. v. Little Squaw Gold Mining Company" on Justia Law

Sea Hawk Seafoods, Inc. sued the City of Valdez for damages after Valdez applied for a grant from the State of Alaska for funding to convert Sea Hawk's seafood processing facility into a fish meal plant but then declined to accept the $600,000 grant that the State conditionally awarded to Valdez. On pre-trial motions, the superior court dismissed Sea Hawk's claims for breach of contract, breach of an agreement to negotiate, and breach of a duty to negotiate in good faith. Valdez and Sea Hawk filed cross-motions for summary judgment on Sea Hawk's remaining claim for promissory estoppel, which the court denied. Shortly before trial, the court dismissed Sea Hawk's promissory estoppel claim as a discovery sanction. Sea Hawk and Valdez both appealed. Upon review, the Supreme Court affirmed: Sea Hawk's claims were based on statements made and a letter sent by the Valdez City Manager to the owner of Sea Hawk. Because these communications, even when viewed in the light most favorable to Sea Hawk, were insufficient as a matter of law to support Sea Hawk's claims. The Court reversed the lower court's ruling denying Valdez summary judgment on Sea Hawk's promissory estoppel claim. View "Sea Hawk Seafoods, Inc. v. City of Valdez" 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