Justia Alaska Supreme Court Opinion Summaries

Articles Posted in Civil Procedure
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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

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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

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The City of Valdez in Alaska appealed two orders by the Regulatory Commission of Alaska (RCA) related to the transfer of the Trans-Alaska Pipeline System (TAPS) from BP Pipelines (Alaska) Inc. (BPPA) to Harvest Alaska, LLC. The first order (Order 6) approved confidential treatment of certain financial statements submitted by the oil company and its affiliates. The second order (Order 17) approved the transfer of a required certificate and the authority to operate the pipeline. The Superior Court dismissed Valdez’s appeals, concluding that Valdez lacked standing, failed to exhaust available administrative remedies, and the case was moot. The court also ordered Valdez to pay a portion of the attorney’s fees of the oil company and other companies involved in the proceedings.The Supreme Court of the State of Alaska reversed the dismissal of the appeal of Order 6, affirmed the dismissal of the appeal of Order 17, and vacated the award of attorney’s fees. The court found that Valdez had standing to appeal both orders, the appeals were not moot, and Valdez had exhausted administrative remedies with respect to Order 6 but not Order 17. The court remanded the case for further proceedings. View "City of Valdez v. Regulatory Commission of Alaska" on Justia Law

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In this case, tenants Matthew Raines and Melissa Clayton complained to their landlord, Tuyen Dinh, about the habitability of their rented unit, particularly due to issues with their utilities and the presence of unauthorized tenants in the building. The tenants withheld rent and requested reimbursement for additional utilities costs. When Dinh refused and subsequently evicted the tenants for nonpayment of rent, a dispute ensued. The Superior Court of the State of Alaska held a damages trial, finding largely in favor of the tenants.The Supreme Court of the State of Alaska affirmed the lower court's findings that Dinh failed to maintain the premises in a habitable condition and willfully diminished the tenants' essential services under the Uniform Residential Landlord and Tenant Act (URLTA). However, the Supreme Court reversed the lower court's conclusion that the tenants could recover for the landlord's failure to deliver possession of the property. The Supreme Court also affirmed some aspects of the lower court's award of damages, but reversed those awards that were not supported by the record.The court found that Dinh's violation of housing codes and his conditional use permit diminished the value of the tenants' leasehold by the $8,800 owed in past rent. The court also found that Dinh was responsible for additional costs incurred by the tenants due to the unauthorized use of their utilities by unauthorized tenants in the building. However, the court ruled that the tenants could not recover for Dinh's failure to deliver possession of the property, despite finding that Dinh did not deliver habitable premises at the commencement of the lease. View "Dinh v. Raines" on Justia Law

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In the case of Brett Lane v. the State of Alaska, Department of Family & Community Services, Office of Children’s Services, the Supreme Court of the State of Alaska affirmed the lower court's decision denying the Office of Children's Services's (OCS) post-trial motion for a new trial on liability. The court concluded that the weight of the evidence supported the jury's verdict on Lane's theories of retaliation. However, the court found an error in the jury instruction relating to noneconomic damages caused by a dangerous client, Wilson. As a result, the court vacated the damages judgment and remanded for a new trial solely on noneconomic damages. The court also remanded the matter back to the lower court for an evidentiary hearing on OCS's claim that the jury award duplicated workers’ compensation benefits that Lane received. The court held that OCS should be given the opportunity to prove that the jury award created an impermissible duplication of damages. View "State of Alaska v. Lane" on Justia Law

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In the State of Alaska, a woman, Lacie Chance, left her boyfriend, Jason Armstrong, in California and relocated to Alaska with their daughter. She filed for a domestic violence protective order (DVPO) against Armstrong in Alaska, alleging seven years of physical and mental abuse. The superior court issued temporary 20-day protective orders and a long-term protective order against Armstrong, who had never been to Alaska. Armstrong appealed, arguing that the court lacked personal or subject matter jurisdiction. While the Supreme Court of the State of Alaska agreed with the lower court that it had subject matter jurisdiction to hear the case, it concluded that the superior court lacked the personal jurisdiction necessary to impose affirmative and long-term obligations on Armstrong, who had no contacts with Alaska. The court emphasized that due process requires either general or specific jurisdiction over a defendant. In this case, Armstrong had no contacts with Alaska, and therefore, the court did not have personal jurisdiction over him. The court concluded that the long-term DVPO could not stand because it imposed significant and potentially long-lasting restrictions and obligations on Armstrong. The DVPO was vacated. View "Armstrong v. Chance" on Justia Law

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In this case, the Supreme Court of the State of Alaska reversed the Superior Court's decision and held that the Department of Corrections' policy change regarding the definition of "firm release date" for prisoners was a regulation that required compliance with the rulemaking procedures of the Administrative Procedures Act (APA). The Department of Corrections had changed its interpretation of "firm release date" twice. Initially, a prisoner's release date on discretionary parole was not considered a "firm release date." In 2016, the Department changed this interpretation and considered a discretionary parole release date as a "firm release date." However, in 2019, the Department reverted to its initial interpretation. The plaintiff, Trevor Stefano, a prisoner, argued that this change in policy violated the APA because it amounted to revising a regulation without going through the APA’s rulemaking process. The Supreme Court agreed with Stefano, noting that the Department's actions were a changed interpretation of existing regulation that had to be adopted through rulemaking. Because the Department did not follow the rulemaking procedure, the Court reversed the Superior Court's decision and remanded the case for further proceedings. View "Stefano v. State of Alaska, Department of Corrections" on Justia Law

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In this case in the Supreme Court of the State of Alaska, a candidate who narrowly lost an election brought a case alleging that the Division of Elections had improperly allowed some voters to cast ballots without meeting constitutional and statutory residency requirements. The court upheld the election results in favor of the opposing candidate and dismissed the losing candidate's lawsuit. The winning candidate then moved for attorney’s fees and costs, asserting that certain claims made in the election contest were frivolous or made in bad faith. The court agreed and awarded the winning candidate full attorney’s fees and costs related to those claims. The losing candidate appealed, arguing that he was protected from an adverse attorney’s fees award as a constitutional claimant and that the court failed to follow proper procedure for imposing fees and costs as sanctions. The Alaska Supreme Court held that the unsuccessful candidate’s constitutional claims were not frivolous or made in bad faith and reversed the award of attorney’s fees and costs. However, the court ruled that the unsuccessful candidate is not exempt from sanctions for violating court rules after notice and an opportunity to be heard and remanded for further proceedings to determine whether sanctions could be awarded for violations of court rules. View "Pruitt v. State of Alaska, Division of Elections" on Justia Law

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The Supreme Court of the State of Alaska was asked to determine whether the question of a deceased worker's status as an employee or independent contractor under the Alaska Worker's Compensation Act should be determined by a jury or a judge. The lawsuit was initiated by the estate of Nicholson Tinker, a worker who was killed in a construction accident while working for Mark Welty, doing business as North Country Services. Welty had no workers' compensation coverage at the time of the accident. Tinker's estate argued that he was an employee and that under the Act, Welty was presumed negligent because he had no compensation coverage. Welty argued that Tinker was an independent contractor, hence the Act did not apply.The superior court decided that the question of employee status was an issue for the jury to decide. The estate appealed this decision, arguing that the Supreme Court's earlier decision in Benson v. City of Nenana determined that a judge, not a jury, should decide the issue of a worker's status under the Act.The Supreme Court of the State of Alaska agreed with the estate, holding that the superior court must determine whether Tinker was an employee or independent contractor under the Act as a preliminary issue before trial. The Court reasoned that the applicability of the Act is a legal determination with factual underpinnings that the court should decide as a preliminary matter. The Court also noted that determining the employee status promptly is significant due to its potential impact on basic issues such as the type of action a party can bring or the burden of proof for negligence. Therefore, the Court reversed the superior court’s order that the jury decides the issue of employee status and remanded for further proceedings. View "Leona Seal, Personal Representative of the Estate of Nicholson J. Tinker v. Mark C. Welty D/B/A North Country Services" on Justia Law

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In the case before the Supreme Court of the State of Alaska, the petitioner, Eric McDonald, an employee of a subcontractor, suffered injuries during the renovation of a high school. He sued Architects Alaska, Inc. and BBFM Engineers, Inc., alleging that they negligently failed to exercise reasonable care in the design, supervision, implementation, and specifications of the demolition of the renovation project. Before trial, the parties’ attorneys discussed the possibility of a settlement, and the defendants moved to enforce a “walk-away” settlement they claimed had been reached through email correspondence. McDonald, unrepresented at this point, did not file a substantive response to the defendants’ motion. The superior court granted the defendants’ motion and dismissed the case.About a year later, McDonald moved for relief from judgment under Alaska Rule of Civil Procedure 60(b), arguing that he had never given his attorney authority to settle the case. A different superior court judge granted the motion, finding that factual issues precluded summary judgment on whether a settlement agreement existed, that the earlier dismissal was erroneous as a law matter, and that extraordinary circumstances otherwise entitled McDonald to Rule 60(b) relief. The defendants petitioned for review, and the Supreme Court of the State of Alaska reversed the ruling on the ground that McDonald’s Rule 60(b) motion was not filed within a reasonable time. View "BBFM Engineers, Inc. v. McDonald" on Justia Law