Justia Alaska Supreme Court Opinion Summaries

The State Commission for Human Rights brought an action on behalf of an employee who alleged that her employer’s racist and insensitive remarks created a hostile work environment. The Commission ultimately found that the employee did not suffer a hostile work environment, but it denied the employer’s request for attorney’s fees. The employer appealed on the issue the fees, arguing that it was entitled to fees as the prevailing party and because it raised affirmative defenses under the Alaska and United States Constitutions. After review of the specific facts entered on the Commission's record, the Supreme Court found no reversible error and affirmed the Commission’s denial of fees. View "Ace Delivery & Moving, Inc. v. Alaska State Commission for Human Rights" on Justia Law

Arthur Kinnan lived in a residence as part of a substance abuse treatment program operated by Sitka Counseling. Funding for that program ended, and Sitka Counseling informed Kinnan that he would be required to vacate. Kinnan filed suit against Sitka Counseling and two of its staff members, unsuccessfully alleging several torts based on the defendants’ conduct when removing him from the premises, violations of Alaska’s Landlord Tenant Act, and deprivation of constitutional rights under 42 U.S.C. 1983. Kinnan argued on appeal to the Supreme Court that the superior court wrongfully denied a continuance to allow him to seek counsel, wrongfully excluded the testimony of a late-disclosed witness and two affidavits, and improperly facilitated questioning regarding Kinnan’s mental disability. The Supreme Court concluded that any error resulting from the exclusion of Kinnan’s witness was harmless and saw no abuse of discretion in the superior court’s denial of Kinnan’s continuance, its exclusion of the affidavits as hearsay, or its consideration of Kinnan’s mental disability. Furthermore, the Court also rejected Kinnan’s argument that the superior court’s adverse rulings created an appearance of judicial bias. View "Kinnan v. Sitka Counseling" on Justia Law

Paul Stavenjord, a Buddhist inmate, asked to receive a Kosher diet and to be permitted to purchase a prayer shawl. Prison officials at the Alaska Department of Corrections denied his requests. Stavenjord filed a complaint alleging violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA) and various constitutional provisions. The superior court granted the Department's motion for summary judgment, concluding that Stavenjord had failed to demonstrate: (1) that a Kosher diet and prayer shawl were necessary for the practice of his religion; (2) that he was sincere in his requests for religious accommodation; and (3) that the Department's lack of accommodations substantially burdened the practice of his religion. Under Alaska's summary judgment standard, the initial burden falls on the moving party: the Department. Furthermore, religious necessity was not an element of RLUIPA. Because summary judgment was granted by placing the initial burden on the non-moving party and by focusing on Stavenjord's failure to make an evidentiary showing not required under RLUIPA, the Supreme Court reversed and remanded for further proceedings. View "Stavenjord v. Schmidt" on Justia Law

A public employee filed a complaint with the Commission for Human Rights in 2007 alleging employment discrimination and filed another complaint with the superior court in 2012. Upon learning of the 2012 complaint, the executive director dismissed the 2007 complaint, citing AS 18.80.112(b)(4). Alaska Statute 18.80.112(b)(4) gives the executive director of the Alaska State Commission for Human Rights discretion to dismiss a complaint of employment discrimination if the complainant initiates an action in another forum "based on the same facts." Upon review, the Supreme Court concluded that the executive director had a proper statutory basis for dismissal because the 2012 civil complaint was "based on the same facts" as those alleged in the 2007 complaint. View "Grundberg v. Alaska State Communication for Human Rights" on Justia Law

Daniel G. appealed an ex parte order authorizing a 72-hour psychiatric evaluation issued after his emergency detention. The evaluation personnel determined that Daniel did not meet the statutory criteria for involuntary commitment, and he was released before the expiration of the 72-hour period. He argued the evaluation order violated his constitutional right to due process because it was issued on an ex parte basis, without notice and a hearing, while he was safely in protective custody. The superior court denied the motion to vacate the evaluation order as moot in light of Daniel’s release. After careful consideration of the circumstances of this case, the Supreme Court concluded that although Daniel's appeal was moot, the public interest exception to the mootness doctrine applied. The Court therefore reached the merits of his due process claim: the 72-hour evaluation order and the statutory evaluation procedures did not violate due process, and the Court affirmed the evaluation order. View "In Re Necessity for the Hospitalization of Daniel G." on Justia Law

The Alaska Workers' Compensation Board denied a death benefit claim filed by the decedent's same-sex partner because the death benefit statute grants benefits only to a worker’s "widow or widower" as defined by statute. The Board construed these terms by applying the Marriage Amendment to the Alaska Constitution, which defined marriage as "only between one man and one woman," thus excluding a decedent's same-sex partner. Because this exclusion lacked a fair and substantial relationship to the purpose of the statute, the Supreme Court concluded that this restriction on the statutory definition of "widow" violated the surviving partner's right to equal protection under the law. View "Harris v. Millennium Hotel" on Justia Law

Stephen O.'s parents were concerned that he had suffered a possible psychotic break. They reported his behavior to a mental health clinician. The clinician obtained an ex parte order to take Stephen into custody and transport him to the hospital in Juneau for examination and treatment. The police took him into custody, but due to bad weather he remained in jail for six days before he was transported for evaluation. After a contested hearing, the superior court found by clear and convincing evidence that Stephen was gravely disabled under AS 47.30.915(7)(B) and issued an order for a 30-day involuntary commitment. Stephen appealed that order. Because the superior court’s conclusion that the man was gravely disabled was not supported by clear and convincing evidence, the Supreme Court reversed and vacated the superior court’s 30-day involuntary commitment order.View "In Re Necessity for the Hospitalization of Stephen O." on Justia Law

In 2011 the superior court entered a 30-day involuntary civil commitment order for Mark V. after the court conducted an evidentiary hearing and found that Mark posed a "substantial risk . . . of harming others." Mark argued on appeal that the court erred in that finding. Because his period of commitment under that order has expired and Mark was soon released from custody, his appeal was technically moot. But he argued that the collateral consequences exception to the mootness doctrine nonetheless justified appellate review of the commitment order. The circumstances (including four civil commitment orders entered against Mark earlier in 2011 and the absence of any indication that the November 2011 commitment will result in any additional adverse collateral consequences) convinced the Supreme Court that the exception was not satisfied. The Court therefore did not reach the merits of Mark's appeal and dismissed it as moot. View "In Re Necessity for the Hospitalization of Mark V." on Justia Law

The respondent in this mental health commitment proceeding argued that the delay between his detention and his involuntary commitment hearing violated time limits imposed by statute and due process of law. After review of the case, the Supreme Court concluded that the relevant statutory time limit began upon a respondent’s arrival at an evaluation facility, that there was no obvious or prejudicial statutory violation in this case, and that the delay in this case did not violate due process. Furthermore, the Court concluded that the respondent’s appeal of his involuntary medication order was moot. View "In Re Necessity for the Hospitalization of Gabriel C." on Justia Law

The Alaska State Commission for Human Rights dismissed Gregg Conitz's complaint against his employer, Teck Alaska Incorporated. In his complaint, Conitz alleged the company discriminated in its promotion decisions. The superior court dismissed Conitz's appeal as moot, finding that the same claims had already been decided by a federal court and that the doctrine of res judicata precluded further claims if remanded to the Commission. Conitz appealed. Finding no reversible error, the Supreme Court affirmed the superior courts decision. View "Conitz v. Alaska State Commission for Human Rights" on Justia Law