Justia Alaska Supreme Court Opinion Summaries

Appellee Wayne Manning told Appellant Diane Roberson he would give her his share of their jointly purchased mobile home. Without her knowledge, he then transferred title of the mobile home to his name only and sold it to co-Appellee Dennis Wilson. Wilson attempted to terminate Roberson's tenancy in the mobile home. Roberson filed suit in the superior court to be declared the owner of the home. The court concluded that Manning did not give his share of the home to Roberson and that Wilson was a good-faith purchaser and therefore the owner. Roberson appealed, arguing that she is the owner because Manning's gift to her was valid and the sale to Wilson was invalid. Upon review, the Supreme Court vacated the superior court's conclusion that Manning did not give Roberson the home. The Court also vacated the superior court's determination that Wilson was a good-faith purchaser. The case was remanded for additional findings. View "Roberson v. Manning" on Justia Law

Petitioner Eleanor Oakes owned a 7/8 undivided interest in a 20-acre parcel of land in Council, while Respondents David and Sine Holly owned a 1/8 undivided interest in the property. The parties went to court to partition the property, and each agreed to submit up to three partition proposals for the court’s selection after it heard evidence about the choices. The superior court selected one of Petitioner's proposals, and she hired a surveyor to implement the division of the property. The survey revealed a significant error in the map presented to the superior court of the selected proposal. The error resulted in the Hollys acquiring more river frontage than Petitioner had intended in her proposal which was selected by the superior court. Petitioner moved to amend the proposal, but the Hollys urged that the selected proposal be implemented as surveyed. The superior court concluded that under the doctrine of mutual mistake, Petitioner bore the risk of the drafting mistake in her proposals, and it enforced the proposal with the drafting error. But because the error in the property description did not occur in the formation of contract, the Supreme Court in its review concluded that the doctrine of mutual mistake was inapplicable. "Instead, the error occurred during the evidentiary hearing and formed a mistaken factual premise for the trial court's decision." The Court therefore remanded the case back to the superior court to determine whether it was appropriate to grant relief for mistake, and if so, to repartition the property in compliance with state law. View "Oates v. Holly" on Justia Law

Thirty seven years ago, two business partners bought a 160-acre property bordering the Kenai River which they subdivided into 114 lots (Holiday Park Subdivision). The partners reserved an easement across Lot 30 for the benefit of all Holiday Park owners, but disagreements arose over the permissible uses and geographic boundaries of the easement. In 2004, the owner of Lot 30 sold it to Kenai River Airpark, LLC. One of the developers of Holiday Park sued Kenai River Airpark and the Airpark Owners Association to prevent their use of Lot 30. The superior court ruled that members of the Airpark Owners Association could use Lot 30 as long as they did not interfere with Holiday Park owners’ use of the easement. The superior court also ruled that the easement’s scope was limited to a defined path shown on the Holiday Park plat, but that permissible uses of the easement included boat launching, bank fishing, and river access. The Holiday Park developer appealed. Because Holiday Park’s plat unambiguously described the easement’s scope as “30' BOAT LAUNCH ESM’T,” the Supreme Court reversed the superior court’s ruling permitting more expansive use. However, the Court affirmed the superior court’s order regarding the geographic bounds of the easement; the original developer did not establish an expanded easement by prescription, implication, inquiry notice, or estoppel. View "HP Limited Partnership v. Kenai River Airpark, LLC" on Justia Law

Native nonprofit corporation Dena Nena Henash (d/b/a Tanana Chiefs Conference) applied to the Fairbanks North Star borough assessor for charitable-purpose tax exemptions on several of its properties. The assessor denied exemptions for five of the parcels, concluding that they did not meet the exemption’s requirements. The superior court affirmed the denial as to four of the properties and remanded the case for consideration of one property back to the assessor, who granted the exemption. The Nonprofit appealed the denial of exemptions for three of the remaining properties plus a portion of the fourth, and appealed the superior court’s award of attorney’s fees to the Borough. Because the properties in question were used exclusively for charitable purposes, the Supreme Court reversed the assessor’s determination on the four appealed properties, vacated the attorney’s fees award, and remanded for an award of fees. View "Dená Nená Henash v. Fairbanks North Star Borough" on Justia Law

Renaissance Resources Alaska, LLC (Renaissance) partnered with Rutter & Wilbanks Corporation (Rutter) to develop an oil field. Renaissance and Rutter acquired a lease to the entire working interest and the majority of the net revenue interest of the field. They then formed a limited liability company, Renaissance Umiat, LLC (Umiat), to which they contributed most of the lease rights. But when they formed Umiat, Renaissance and Rutter did not contribute all of their acquired lease rights to the new company: they retained a 3.75% overriding royalty interest (ORRI). Rutter was eventually unable to meet the capital contributions required by Umiat's operating agreement and forfeited its interest under the terms of the agreement. Rutter filed suit against Renaissance seeking a declaratory judgment that it was entitled to half of the retained 3.75% ORRI. Renaissance argued why it deserved the entire 3.75%: (1) Renaissance held legal title to the 3.75% ORRI; and (2) Rutter could only obtain title through an equitable remedy to which Rutter is not entitled. Upon review, the Supreme Court affirmed the superior court’s conclusion that Renaissance's characterization was inaccurate and that Rutter was entitled to title to half of the 3.75% ORRI. Furthermore, Renaissance argued that the superior court should have found an implied term that Rutter would forfeit its share of the 3.75% ORRI if Rutter failed to contribute its share of expenses. The Supreme Court affirmed the superior court’s determination that there was not such an implied term in the agreement. View "Renaissance Alaska, LLC, v. Rutter & Wilbanks Corporation" on Justia Law

In 2004 and 2005, while allegedly bedridden and taking prescription pain medication, Plaintiff Gregory Erkins took out two successive loans on his house. The proceeds of the second, larger loan were used in part to pay off the first. In early 2007, Plaintiff ceased making regular payments and this loan fell into default. His house was listed for foreclosure sale. Also, at some point between February 2005 and November 2007, the loan was assigned from Ameriquest Mortgage Company to Appellee Bank of New York Trust Company, N.A. Acting pro se, Plaintiff filed suit in the superior court against Alaska Trustee, LLC, Bank of New York (the current holder of the loan), and JP Morgan Chase Bank, N.A. (JP Morgan) (a party apparently unconnected to the proceedings except in that Bank of New York was listed as its successor). Plaintiff disputed the terms of the second loan, and argued fraud as well as lack of contractual capacity at the time of its origination. Several months after Plaintiff filed his complaint, as a trial date was about to be set, counsel for the defendants presented Plaintiff with a forbearance agreement. This agreement contemplated postponing the foreclosure sale in exchange for $2,000 monthly payments. Plaintiff executed this agreement. Allegedly unbeknownst to Plaintiff, the agreement also contained a waiver of claims broad enough to cover his claims against the defendants. Nine months later, the defendants moved for summary judgment, arguing that this waiver of claims functioned as a settlement and released all of Plaintiff's claims in this suit. The superior court granted summary judgment to the defendants, finding no genuine issue of material fact barring judgment that they were not liable for any tort of Ameriquest, and that Plaintiff had released his claims in the forbearance agreement. Upon review, the Supreme Court affirmed that portion of the superior court’s decision finding that defendants could not be held liable for the alleged torts of Ameriquest. But the Court reversed that portion of the superior court’s order concluding that Plaintiff released his claims against the defendants by entering into a forbearance agreement because a genuine issue of material fact existed as to whether the inclusion of the waiver of claims provision in the forbearance agreement constituted constructive fraud. View "Erkins v. Alaska Trust, LLC" on Justia Law

A property owner appealed a judgment that allowed foreclosure on a borough property tax lien, arguing that the borough’s foreclosure was legally flawed and that the borough’s attorney should have been sanctioned for maintaining the foreclosure against his property. Because the superior court did not err in concluding there were no legal flaws in the foreclosure, and because therefore there was no basis to sanction the borough’s attorney, the Supreme Court affirmed the judgment in all respects. View "Lot 04B & Block 83 Townsite v. Fairbanks North Star Borough" on Justia Law

Two men bought an island. After a dispute, they agreed that one would keep the island, while the other would receive a one-time payment and an option to buy the island at a fixed price, adjusted for inflation, if the owner ever chose to sell it. Years passed, the value of the island rose, far outpacing inflation. But the owner never elected to sell. Instead, he eventually conveyed the island to his sister, as a gift. The option holder sued. The superior court held on summary judgment that the option remained viable, but that the gift was not improper. The option holder appealed. Upon review, the Supreme Court affirmed the superior court's interpretation of the option agreement, but because material facts were in dispute concerning contractual claims and allegations that the option holder's conveyance was fraudulent, the Court reversed and remanded the superior court's grant of summary judgment on those claims. View "Shaffer v. Bellows" on Justia Law

The superior court interpreted a statutory preference for the purchase of state land in a manner that disqualified Appellant Melvin Gillis, from which he appealed. Appellant is a professional sport hunting and fishing guide. He obtained a 25-year lease of five acres of state land in April 1989. Appellant built a lodge on the land, and the operation of the lodge and his guiding business were his principal sources of income. In 2005, the state Department of Natural Resources (DNR) conveyed lands, including the land Appellant leased, to Aleutians East Borough. DNR also transferred its interest in Appellant's lease to the Borough. Appellant offered to purchase the land in November 2005. The Borough Assembly rejected Appellant's offer but proposed a new lease agreement. Appellant did not execute the proposed lease, and in 2007 he claimed he was eligible to purchase the land under state law. The Borough then filed a declaratory judgment action, asking the superior court to determine whether Appellant qualified for a preference right to purchase the land. The issue on appeal was whether the applicable statute required an applicant to enter land while it was under federal ownership as a condition of the preference right. The superior court concluded that the plain meaning of the statute required an applicant to enter land when it was under federal ownership before the federal government conveyed the land to the state. The court entered summary judgment in favor of the Borough and DNR. Upon review, the Supreme Court affirmed the superior court's interpretation of the applicable statute and its summary judgment decision. View "Gillis v. Aleutians East Borough" on Justia Law

Landowner Appellant Charles Miller contracted with Handle Construction Company, a manufacturer of pre-fabricated steel hangars, to erect a steel hangar on his land. After completing its work, the Company sued Appellant for unanticipated costs it incurred as a result of manufacturing defects in the hangar. Appellant made an offer of judgment which the Company accepted. When the Company received a separate payment from the hangar's manufacturer, Appellant refused to pay the full amount, arguing that an offset was warranted. The superior court rejected Appellant's argument and ordered him to pay the full amount of the offer. The case was submitted to the Supreme Court for review, but the Court determined that the basis for the superior court's decision was unclear. The Court reversed the decision and remanded the case for additional factual findings. View "Miller v. Handle Construction Company" on Justia Law