Justia Alaska Supreme Court Opinion Summaries

A longtime Alaska resident with extensive experience in personal-use and commercial fishing brought suit against the State of Alaska, alleging that the State’s management of chinook and chum salmon populations in the Yukon and Kuskokwim Rivers violated the sustained yield principle mandated by the Alaska Constitution. The plaintiff claimed that the significant decline in these salmon populations since statehood was evidence of unconstitutional management. He did not challenge any specific policy, regulation, or action, but instead sought a declaration that the State’s management had been unconstitutional for decades and requested injunctive relief to compel the State to fulfill its sustained yield obligations.The Superior Court for the Fourth Judicial District, Bethel, granted the State’s motion to dismiss for failure to state a claim. The court found that the claims presented nonjusticiable political questions reserved for the legislative branch, that the plaintiff failed to allege a concrete injury or identify specific State actions causing harm, and that deference to agency expertise was warranted in the absence of a challenge to a particular policy or action.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s dismissal. The Supreme Court held that the claims for injunctive relief were nonjusticiable because they would require the judiciary to make initial fisheries policy determinations, a function constitutionally committed to the legislative and executive branches. The Court further held that the claim for declaratory relief was not justiciable because it would not clarify or settle the legal relations between the parties, as it did not identify specific actions or policies to be addressed. The Court concluded that, absent a challenge to a particular State action or policy, the claims did not present an actual controversy suitable for judicial resolution. View "Forrer v. State of Alaska" on Justia Law

Several months before an election, complaints were filed with the Alaska Public Offices Commission alleging that two political groups, A Stronger Alaska and the Republican Governors Association, had violated Alaska’s campaign finance laws by coordinating with a gubernatorial campaign and failing to comply with disclosure requirements. The Commission initiated expedited proceedings, held hearings where officials from the groups testified, and then chose not to make a final determination on the alleged violations. Instead, the Commission remanded the matters to its staff for further investigation on a regular, non-expedited basis. The Commission’s staff subsequently issued administrative subpoenas seeking documents and communications from the groups, but the groups refused to comply.The Commission sought judicial enforcement of its subpoenas in the Superior Court for the State of Alaska, Third Judicial District. The groups opposed enforcement, arguing that the subpoenas were unnecessary because the Commission already had relevant testimony, that further investigation was barred by res judicata, and that the process violated their due process rights. They also challenged the constitutionality of the statutory scheme authorizing the expedited process. The superior court rejected all of these arguments, granted summary judgment in favor of the Commission, and ordered enforcement of the subpoenas.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s decision. The court held that the subpoenas were not unreasonable or oppressive simply because prior testimony had been given, as documentary evidence could still be relevant. The court also held that res judicata did not apply because the Commission had not issued a final decision on the merits, and that the process did not violate substantive due process or result in an absurd or unconstitutional statutory scheme. The court affirmed the order granting summary judgment to the Commission. View "Republican Governors Association v. Hebdon" on Justia Law

The case involves the appellant, Gregory Smith, challenging the Municipality of Anchorage's decision to abate unauthorized campsites in Davis Park. The Anchorage Municipal Code (AMC) outlines procedures for campsite abatement, including posting a notice and allowing for an appeal to the superior court. In June 2022, the Municipality posted a notice in Davis Park, advising that the area was not legal for storage or shelter and that any personal property would be removed and disposed of as waste after ten days. Smith and five others appealed the abatement, arguing it violated due process and the Eighth Amendment.The superior court dismissed the appeal, agreeing with the Municipality that its jurisdiction was limited to reviewing the legal sufficiency of the posted notice, not the abatement decision itself. The court noted that the appellants did not challenge the notice's compliance with the Code, thus leaving no issues for the court to decide. The court also observed that the appellants' claims were not without merit and suggested that a civil suit could address their concerns.The Supreme Court of the State of Alaska reviewed the case and concluded that the superior court's jurisdiction was not limited to the notice's legal sufficiency. The court held that the superior court has jurisdiction to review the substantive decision to abate the campsite, including constitutional challenges. The court reversed the superior court's decision and remanded the case for further consideration of the constitutional issues raised by Smith. The court also directed the superior court to determine if the administrative record was sufficient for meaningful appellate review and to take necessary steps to ensure it has an adequate record. View "Smith v. Municipality of Anchorage" on Justia Law

Yako Collins was convicted of first-degree sexual assault in 2009 and sentenced to 25 years with five years suspended. Collins requested referral to a three-judge sentencing panel, arguing that his lack of significant criminal history and good character warranted a sentence outside the presumptive range. The superior court denied his request, and Collins appealed.The Alaska Court of Appeals in Collins I identified two non-statutory mitigating factors that could justify referral to the three-judge panel: the defendant's lack of a history of unprosecuted offenses and normal prospects for rehabilitation. The court remanded the case to the superior court for reconsideration. While the case was pending, the Alaska Legislature amended the relevant statutes in 2013, explicitly rejecting these mitigating factors as standalone bases for referral. The superior court, applying the amended statutes, affirmed Collins's original sentence, and Collins appealed again.In Collins II, the Court of Appeals concluded that the 2013 legislative amendments merely clarified existing law and did not violate the ex post facto clause. The court held that Collins could not seek referral to the three-judge panel based solely on the factors identified in Collins I but could argue for referral based on the totality of circumstances.The Alaska Supreme Court reviewed the case and held that the 2013 amendments could not be applied retroactively to Collins, as they were substantive changes to the law. The court emphasized the separation of powers and the prohibition on ex post facto laws, concluding that the legislature could not retroactively overrule a binding judicial interpretation. The case was remanded to the Court of Appeals to determine whether the 2013 amendments were procedural or substantive. View "Collins v. State of Alaska" on Justia Law

An Alaska hunter challenged a state regulation that allocates permits for hunting Kodiak brown bears, with at least 60% reserved for Alaska residents and no more than 40% for nonresidents, who must generally hunt with a professional guide. The hunter argued that this allocation grants nonresidents a special privilege in violation of the Alaska Constitution’s principle of equal access to fish and game and that it fails to manage resources for the maximum benefit of Alaskans.The Superior Court of Alaska, Third Judicial District, upheld the regulation, concluding that it did not grant an exclusive right to nonresidents and that the allocation system was within permissible bounds. The court found that the regulation did not exclude residents from hunting and that the allocation balanced various interests, including economic benefits and conservation.The Supreme Court of the State of Alaska reviewed the case and affirmed the lower court’s decision. The court held that the regulation did not violate the equal access clauses of the Alaska Constitution. It reasoned that treating residents and nonresidents differently does not, in itself, violate the constitution, and that the regulation did not grant nonresidents an unconstitutional special privilege. The court also found that the state could consider economic benefits when managing wildlife resources and that the Board of Game had taken a hard look at the relevant factors, including conservation and economic benefits, when establishing the permit system. Thus, the regulation was consistent with the constitutional duty to manage resources for the maximum benefit of Alaskans. View "Cassell v. State of Alaska, Department of Fish & Game" on Justia Law

Kenneth Jouppi, the owner of an airplane, was convicted of transporting beer into the village of Beaver, Alaska, which prohibits the importation of alcoholic beverages. Following his conviction, Alaska law mandated the forfeiture of his airplane as it was used to commit the offense. Jouppi argued that the forfeiture violated the Excessive Fines Clause of the U.S. Constitution.The District Court of the State of Alaska, Fourth Judicial District, Fairbanks, initially declined to order the forfeiture on statutory grounds. The State appealed, and the Court of Appeals reversed, mandating the forfeiture. On remand, the trial court again declined to order the forfeiture, this time on constitutional grounds, finding it unconstitutionally excessive. The State appealed again, and the Court of Appeals vacated the trial court’s ruling, remanding for further fact-finding, as it concluded the trial court failed to correctly apply the test for excessive fines from United States v. Bajakajian.The Supreme Court of the State of Alaska reviewed the case. It held that the forfeiture of the airplane did not violate the Excessive Fines Clause because it was not grossly disproportional to the gravity of the offense. The court found that the forfeiture was punitive and thus a "fine" under the Eighth Amendment. Applying the Bajakajian factors, the court concluded that the forfeiture was not excessive given the nature and extent of the crime, the legislative intent behind the statute, and the harm caused by the offense. The court also noted that Jouppi failed to preserve his arguments under the Alaska Constitution and the Sixth Amendment, and thus did not address them. The judgment of the Court of Appeals was vacated, and the case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Jouppi v. State of Alaska" on Justia Law

The case involves the State of Alaska's statutes that allow local school districts to operate correspondence study programs and provide public funds for educational expenses. Parents of public school students sued the State, arguing that these statutes violated the Alaska Constitution by allowing public funds to be used for private school tuition, which they claimed was unconstitutional.The Superior Court of Alaska ruled that the statutes were facially unconstitutional and invalidated them entirely. The court did not address the narrower question of whether the statutes were unconstitutional when applied to allow public funds to be used for private school tuition. The decision was appealed to the Supreme Court of Alaska.The Supreme Court of Alaska reviewed the case and determined that the Superior Court's ruling went too far. The Supreme Court noted that the statutes allowed for a substantial number of constitutionally valid uses of allotment funds, such as purchasing books, supplies, and other educational materials. The court emphasized that even if using allotment funds for private school tuition were unconstitutional, it would not justify invalidating the entire statutes.The Supreme Court vacated the Superior Court's judgment and remanded the case for further proceedings. The court instructed that the proper parties must be joined, and the Superior Court must first determine whether the statutes actually permit the use of allotment funds for private school tuition before addressing the constitutionality of such use. The Supreme Court did not decide whether using allotment funds for private school tuition is constitutional, leaving that question open for further consideration. View "State of Alaska, Dept. of Education & Early Development v. Alexander" on Justia Law

A group of foster children challenged the Office of Children’s Services (OCS) for using their federal Social Security benefits to reimburse itself for foster care costs. The children claimed this practice violated their due process and equal protection rights under the Alaska Constitution and sought restitution. The Superior Court of Alaska found a due process violation and ordered OCS to notify foster children about its practice regarding Social Security benefits. However, the court rejected the equal protection and restitution claims, deeming them preempted by federal law.The Superior Court held that OCS violated due process by not informing foster children about their Social Security benefits and the potential financial advantages of having a private representative payee. The court ordered OCS to provide notices explaining the concept of a representative payee, the consequences of OCS being the payee, and the possibility of proposing an alternative payee. OCS argued that complying with the notice order would violate federal privacy laws, but the court modified its order to address these concerns.The Supreme Court of Alaska reviewed the case and affirmed the Superior Court’s conclusions. The Supreme Court held that the due process claim and the court’s notice order were not preempted by federal law. The court determined that foster children have a property interest in knowing about their Social Security benefits and the ability to nominate a private payee. The court found that OCS’s systematic practice of using benefits to reimburse itself without notice created a high risk of depriving children of their rights.The Supreme Court also held that the equal protection claim was preempted because it would conflict with federal regulations governing the use of Social Security benefits. The court concluded that OCS’s practice of using benefits for foster care costs was permissible under federal law. Finally, the court rejected the proposed remedies of disgorgement and creating a trust, as they would constitute impermissible attachments on federal benefits and were preempted by federal law. View "State of Alaska, Department of Health and Social Services v. Z. C." on Justia Law

A school principal used the school's printer after hours to create a coaster as a retirement gift for a friend. The coaster design contained the School District's official logo but altered the District's motto in a disrespectful manner. A custodian took pictures of the coaster, which were shared on social media, leading to public outrage. The principal left the community the next day. The District proposed to terminate him for incompetence and violating anti-harassment policies. After a brief pretermination hearing, the District terminated the principal. The principal appealed, and the Board upheld the termination following an additional hearing.The principal then appealed to the superior court, which also affirmed his termination. The court found that the District had grounds to terminate the principal due to substantial noncompliance with District rules and regulations and that the community's reaction to the coaster was reasonable. The court also rejected the principal's free speech arguments, stating that his speech was not protected under the First Amendment. The court acknowledged that the pretermination hearing process was flawed but deemed the error harmless due to the subsequent post-termination hearing.The Supreme Court of the State of Alaska reviewed the case. The court held that the Board had a reasonable basis to terminate the principal for incompetency under AS 14.20.170(a)(1) due to his inability to perform his duties effectively after the incident. The court also concluded that the principal's termination did not violate his free speech rights under AS 14.20.095 or the First Amendment. However, the court found that the pretermination hearing process did not provide sufficient due process, as the principal was not informed of his right to call witnesses. The court affirmed the termination but reversed the superior court's decision denying back pay, awarding back pay through the date of the Board's post-termination hearing decision. View "Stirling v. North Slope Borough School District" on Justia Law

A resident of Alaska filed a lawsuit challenging amendments to the State’s predator control program. The resident claimed that after the changes were implemented, she observed a noticeable decrease in the brown bear population at Katmai National Park, where she frequently visited to view bears. She argued that the Board of Game violated its constitutional and statutory duties by not providing adequate notice and opportunities for public input before adopting the changes, which expanded the program to target bears.The Superior Court of Alaska, Third Judicial District, dismissed the complaint, concluding that the resident lacked standing and was not entitled to a declaratory judgment on the validity of the regulatory change. The court also awarded attorney’s fees to the Board of Game and the Commissioner of the Department of Fish & Game.The Supreme Court of the State of Alaska reviewed the case and held that the resident had standing because she demonstrated an injury to her interest in viewing bears at Katmai National Park, which was sufficient to show standing. The court also concluded that she was entitled to a declaratory judgment on the validity of the regulation. The Supreme Court reversed the dismissal of her complaint, vacated the associated award of attorney’s fees, and remanded the case for further proceedings. View "Bittner v. State of Alaska" on Justia Law