Justia Alaska Supreme Court Opinion Summaries

In a prison discipline proceeding, prisoner William Johnson was found guilty of possessing contraband. He appealed his punishment to a discipline committee, which affirmed the decision. Represented by counsel, Johnson appealed to the superior court, alleging that the Department of Corrections had deprived him of due process. The court granted the State’s unopposed motion to dismiss the appeal on the ground that the prisoner’s statement of points on appeal was deficient. When Johnson moved for reconsideration but made no attempt to remedy the deficiency, the superior court denied his motion and awarded the State attorney’s fees. Johnson appealed the dismissal and the award of attorney’s fees. Finding no error, the Supreme Court affirmed. View "Johnson v. Dept. of Corrections" on Justia Law

In a 2007 ruling, the Alaska Supreme Court recognized that the State had "compelling interests" in aiding parents to help their minor children make informed and mature pregnancy-related decisions, and at that time, the Court indicated that a parental notification law might be implemented without unduly interfering with minors’ fundamental privacy rights. The 2010 voter-enacted Parental Notification Law revived an exception in the existing medical emancipation statute, creating considerable tension between a minor’s fundamental privacy right to reproductive choice and how the State could advance its compelling interests. By this 2016 opinion, the Alaska Court concluded that the Notification Law violated the Alaska Constitution’s equal protection guarantee and could not be enforced. "But the decision we reach today is narrow in light of the limited State interests offered to justify the Notification Law. The State expressly disclaims any interest in how a minor exercises her fundamental privacy right of reproductive choice, and it does not suggest that it has an interest in limiting abortions generally or with respect to minors specifically. And as a court we are not concerned with whether abortion is right, wrong, moral, or immoral, or with whether abortions should be available to minors without restriction. We are concerned only with whether, given its stated underlying justifications, the current Notification Law complies with the Alaska Constitution’s equal protection guarantee — and it does not." View "Planned Parenthood of the Great Northwest v. Alaska" on Justia Law

Defendant Aaron Young was accused of involvement in a shooting and convicted at trial, in part on the strength of three eyewitness identifications. He challenged the admissibility of two of the identifications on due process grounds, but the superior court ruled them admissible. Defendant also requested an eyewitness-specific jury instruction, which the superior court refused. Furthermore, defendant argued that he was entitled to a mistrial because of an alleged discovery violation by the State that he learned of mid-trial. The superior court denied his motion, finding that the State had not violated the disclosure rules and alternatively that the defendant had not suffered any prejudice. The defendant was convicted, and the court of appeals affirmed his conviction. On petition to the Alaska Supreme Court, defendant argued not only that his conviction should have been reversed based on the current law on the admissibility of eyewitness identifications, but also that Alaska’s due process clause required the adoption of a new test. He also argued that the superior court erred in failing to give his requested jury instruction and in failing to grant him a mistrial. The Supreme Court held that the superior court erred under the law as it currently existed when it held one of the eyewitness identifications sufficiently reliable to be admitted at trial, but that it did not err in admitting the other. The Court also held that the superior court erred in refusing to give an eyewitness-specific jury instruction but did not err in denying a mistrial. Because the errors were harmless, the Court affirmed defendant’s conviction. In light of the issues raised by this appeal, the Court concluded that the current test for the admissibility of eyewitness identification evidence does not adequately protect the right to due process under the Alaska Constitution. The Court therefore identified factors that courts should consider in future cases when deciding whether to admit eyewitness identification evidence. View "Young v. Alaska" on Justia Law

Linden Fyfe was stopped by police while driving on a stretch of highway designated as a "traffic safety corridor." He was charged and convicted of driving under the influence of alcohol. At sentencing the trial court imposed double the statutory minimum fine, relying on AS 28.90.030(a), that doubled “the fine, or maximum fine,” for any violation of a provision of Title 28 in a traffic safety corridor. The court of appeals reversed. It concluded that despite the statute’s plain language, the legislature intended fines to be doubled only for noncriminal traffic offenses. The Supreme Court disagreed with that rationale, not the appellate court's mandate. The Court concluded that the statute applied to both criminal and non-criminal traffic offenses under Title 28. But the court also held that the plain language of the statute precluded its application to minimum fines such as the one at issue here. On that ground the Court affirmed the court of appeals’ decision to vacate Fyfe’s fine and remanded for imposition of the statutory minimum fine. View "Alaska v. Fyfe" on Justia Law

After a two-day hearing, the University of Alaska Fairbanks (UAF) dismissed Qwynten Richards from her Ph.D. program for failing to respond to feedback from her professors. An Appeals Committee affirmed Richards’s dismissal from the program because it concluded that there were sufficient negative reviews from her professors to support dismissal, and that she had failed to satisfactorily complete a “remediation” assignment given to her after the faculty found she plagiarized parts of a paper. Richards appealed to the superior court. The superior court affirmed, holding that UAF was reasonable in characterizing her dismissal as academic, that it substantially complied with its procedures, and that Richards received due process. It also awarded UAF 10% of its claimed attorney’s fees. Richards appealed to the Supreme Court. But finding no reversible error, the Supreme Court affirmed. View "Richards v. University of Alaska" on Justia Law

In 2014, a petition was filed on behalf of the Seacliff Condominium Association for an order requiring Heather R., the owner of a condominium in Seacliff, to undergo an involuntary 72-hour psychiatric evaluation. The petition alleged that Heather was a threat to “herself . . . and her neighbors” based on “[y]ears of confrontation, threats, aberrant and widely swinging behavior suggesting drug use,” including “taking pictures inside people’s houses, inability to have normal social interactions, [and] lying [in] wait to confront neighbors.” After conducting a statutorily required ex parte screening investigation, which did not include an interview with Heather, the superior court master determined that there was probable cause to believe that she was mentally ill and presented a likelihood of serious harm to others. Heather appealed the evaluation order, claiming that the ex parte investigation violated due process and that the master failed to properly conduct the statutorily required screening investigation. Although this appeal was technically moot, the Supreme Court reached the merits of these claims under the public interest exception. The Court vacated the evaluation order because the superior court master failed to conduct the interview as part of the screening investigation required by statute; the Court did not reach the due process question. View "In Re Necessity for the Hospitalization of Heather R." on Justia Law

John Botson was arrested for driving under the influence. According to a breath test, his blood alcohol level was .141. The police officer informed Botson of his constitutional right to an independent chemical test, which Botson declined. But unbeknownst to Botson and the police officer administering the test, the breath test device had produced an error code related to one of its quality assurance mechanisms. Botson argues that his breath test result was inadmissible under the Anchorage Municipal Code, which required breath tests to be conducted in compliance with methods approved by the Alaska Department of Public Safety. He also argued that suppression was required under the Due Process Clause of the Alaska Constitution because his ignorance of the error code prevented him from knowingly and intelligently waiving his constitutional right to an independent chemical test. But although the administration of Botson’s breath test may not have strictly complied with approved methods, Botson did not contest the district court’s finding that the error code had no bearing on the accuracy of the test. Accordingly, the Supreme Court agreed with the district court’s and the court of appeals’ conclusions that the breath test result was admissible under Alaska's “substantial compliance” doctrine. The Supreme Court also agreed that Botson validly waived his right to an independent chemical test because he had a basic understanding of that right before declining the test. View "Botson v. Municipality of Anchorage" on Justia Law

Article VII, section 1 of the Alaska Constitution required the state legislature to “establish and maintain a system of public schools” open to all children in the state. To fulfill this mandate, the legislature defined three types of school districts according to where the district is located: city school districts, borough school districts, and regional education attendance areas. “[E]ach organized borough is a borough school district”; a borough must “establish[], maintain[], and operate[] a system of public schools on an areawide basis.” Local school boards managed and controlled these school districts under authority delegated by AS 14.12.020. The statute required local borough and city governments to raise money “from local sources to maintain and operate” their local schools. The superior court held that this required local contribution was an unconstitutional dedication of a “state tax or license.” But the minutes of the constitutional convention and the historical context of those proceedings suggested that the delegates intended that local communities and the State would share responsibility for their local schools. Those proceedings also indicated that the delegates did not intend for state-local cooperative programs like the school funding formula to be included in the term “state tax or license.” These factors distinguished this case from previous cases where the Alaska Supreme Court found that state funding mechanisms violated the dedicated funds clause. The Court therefore held that the existing funding formula did not violate the constitution, and reversed the superior court’s grant of summary judgment holding that the funding formula was unconstitutional. View "Alaska v. Ketchikan Gateway Borough" on Justia Law

A non-custodial parent moved to modify a child support order after she quit her job in Anchorage, moved to a remote village, and adopted a subsistence lifestyle. Although the parent acknowledged that she was voluntarily unemployed, she argued that her decision was reasonable in light of her cultural, spiritual, and religious needs. The superior court disagreed and denied the motion. The parent appealed, arguing that the superior court gave inadequate weight to her cultural and religious needs and that the child support order violated her right to the free exercise of her religion. The Supreme Court affirmed, finding that the superior court adequately considered all relevant factors in deciding not to modify the child support order. "And there was no plain error in the court’s failure to anticipate the free exercise claim, which the parent raises for the first time on appeal." View "Sharpe v. Sharpe" on Justia Law

Kelsey George was convicted of four counts of first degree sexual abuse of a minor, three counts of second degree sexual abuse of a minor, and one count of attempted sexual abuse of a minor in the first degree. George appealed, challenging one of the first-degree sexual abuse counts (Count Ten) and the attempted sexual abuse count (Count One). The court of appeals affirmed his convictions on both counts, and George filed a petition for hearing regarding the sufficiency of the evidence supporting the conviction on Count Ten, which was granted. After review, the Alaska Supreme Court concluded that the evidence was insufficient to convict George on Count Ten. Therefore, the Court reversed the court of appeals’ decision in part, and remanded this matter to the superior court for entry of a judgment of acquittal on Count Ten. View "George v. Alaska" on Justia Law