Justia Alaska Supreme Court Opinion Summaries

A miner signed a 20-year lease with a corporate landowner for an easement allowing him access to his limestone-mining operation. The lease included an option to extend it for up to three additional 10-year terms as long as the miner was not in default and gave prior written notice of his intent to extend. At the close of year 19, the miner sent a check prepaying the final calendar year, plus the six weeks following the lease’s expiration date. And after the expiration date the miner sent another check prepaying the next year (year 21) without ever providing the express notice of intent to extend required by the lease. The corporation accepted both of the rent checks. Five months later the corporation sued the miner and his company, contending that he was in breach and the lease had expired. The corporation later amended its complaint to add a claim for forcible entry and detainer seeking to recover possession of the premises by court order, and shortly afterward served the miner with a notice to quit. The court held a hearing nearly 11 months later and granted the forcible-entry claim. Appealing, the miner contended the parties’ dispute was too complex to be resolved through forcible entry and detainer proceedings with limited opportunities for discovery; that the forcible entry and detainer proceeding was unlawful because at the time the claim was asserted the corporation had not yet served the notice to quit; and that the miner’s company was improperly named as a defendant and included in the forcible entry and detainer judgment. Finding no reversible error, the Alaska Supreme Court affirmed the superior court's judgment. View "Caswell, et al. v. AHTNA, Inc." on Justia Law

A boiler exploded in a home owned by a nonprofit regional housing authority, severely injuring a man who lived there. He sued the housing authority in both contract and tort, claiming that his lease-purchase contract included a promise that the authority would inspect the boiler, which it failed to do with reasonable care. After the man dismissed his contract claim, the housing authority asked the court to decide as a matter of law that a breach of a contractual promise could not give rise to a tort claim. But the superior court allowed the man to proceed to trial on his tort claim, and the jury awarded over $3 million in damages, including over $1.5 million in noneconomic damages and separate awards to several of his family members for negligent infliction of emotional distress. The court reduced the man’s noneconomic damages award to $1 million because of a statutory damages cap, but it excluded the family members’ awards from the amount subject to the cap. The housing authority appealed, maintaining it should have been granted a judgment notwithstanding the verdict because the contract did not create a continuing legal duty to inspect the boiler with reasonable care. It also argued it should have been granted a new trial because it had established that the boiler explosion was caused by a product defect rather than negligent inspection. Finally, the authority argued the family members’ damages for negligent infliction of emotional distress should have been included in the amount subject to the statutory damages cap. The man cross-appealed, arguing that the damages cap violated due process because it failed to account for inflation or the severe nature of his physical injuries. After review, the Alaska Supreme Court found no reversible error and affirmed the superior court's judgment on all issues. View "Association of Village Council Presidents Regional Housing Authority v. Mael, et al." on Justia Law

Ramsey Barton sued the City of Valdez after she was severely injured by falling from a tire swing overhanging a cliff in an undeveloped area of a city park. The swing was not built by the City, and Barton alleged the City was negligent in failing to remove it. The superior court assumed on summary judgment that the City had imputed knowledge of the swing, but because there was no evidence the City had a policy to inspect or remove hazards from undeveloped areas of the park, the City was entitled to discretionary function immunity. The court therefore dismissed Barton’s lawsuit against the City. The Alaska Supreme Court reversed, finding that there were "no conceivable policy reasons for declining to remove the unauthorized swing — a human-made hazard that was known, easily accessible, and simple to remove." The Supreme Court found that the failure to remove it was not protected by discretionary function immunity. View "Barton v. City of Valdez" on Justia Law

Gavora, Inc., a real estate company, acquired an existing long-term lease with a purchase option for a municipality-owned property. Dry-cleaning businesses operating on the property contaminated the groundwater both prior to and during the real estate company’s involvement. The municipality knew about, but did not disclose, groundwater contamination at nearby sites when the real estate company ultimately purchased the property. A state agency later notified Gavora and the municipality of their potential responsibility for environmental remediation. Gavora sued the municipality in federal district court; the federal court determined that the parties were jointly and severally liable for the contamination, and apportioned remediation costs. Gavora also sued the municipality in state court for indemnity and further monetary damages, alleging that the municipality had misrepresented the property’s environmental status during purchase negotiations. The superior court ruled in the municipality’s favor, finding the municipality did not actively deceive Gavora; Gavora had reason to know of the contamination; and all physical harm occurred before the sale. Gavora challenged all three findings. Finding no error, the Alaska Supreme Court affirmed the superior court’s decision. View "Gavora, Inc. v. City of Fairbanks" on Justia Law

The superior court determined that an unmarried couple lived for a time as domestic partners and, in connection with the dissolution of the domestic partnership, that a residential property one party purchased was intended to be domestic partnership property. The court ordered a 50/50 division of the partnership equity by way of an equalization payment. The property owner appealed both determinations and the resulting equalization payment. In this opinion, the Alaska Supreme Court addressed only the superior court’s property ruling, concluding that the court erred by determining the residential property was intended to be domestic partnership property. "Even assuming Kristy and John’s relationship rose to the level of a domestic partnership, the factors used to determine intent for property to be domestic partnership property do not support an intent to share ownership, and based on the evidence in the record finding an intent to share ownership of the Rose Lane property was clearly erroneous." The Supreme Court reversed the superior court’s decision, vacated the equalization payment judgment, and remanded for further proceedings. View "McConville v. Otness" on Justia Law

A family trust owned property reachable by an access road that follows an easement across others’ properties. A neighboring couple objected to the trust’s use of the easement, contending the easement grant was invalid and that, if valid, it had been extinguished because of the trust’s failure to insist on its right to use it over the course of several decades, during which time the couple had built a house on the easement and made other use of the area. The trust filed a quiet title action. The superior court decided on summary judgment that the easement was valid; following trial, however, it found that the trust’s action was barred by laches and, alternatively, that the easement had been extinguished by prescription where it met the neighboring couple’s house. The trust appealed. The Alaska Supreme Court found the superior court’s conclusion that the easement was partially extinguished by prescription was supported by its findings of fact, and which were not clearly erroneous. The Court therefore therefore affirmed its decision on that ground. But because the parties were entitled to a final judgment quieting title in accordance with the court’s rulings as affirmed on this appeal, the Supreme Court remanded the case for that purpose. View "Jigliotti Family Trust v. Bloom, et al ." on Justia Law

A junior lienholder who took no steps to protect his interest at a nonjudicial foreclosure sale appealed the superior court’s subsequent summary judgment decision dismissing his claim that the sale process was defective and that the sale thus should have been set aside. Finding no reversible error, the Alaska Supreme Court affirmed the superior court’s decision. View "Thomas v. Joseph P. Casteel Trust" on Justia Law

Property owners sued the Matanuska-Susitna Borough, challenging the validity of easements that cross their property to give access to neighboring residences. The superior court dismissed most of the property owners’ claims on res judicata grounds, reasoning that the claims had been brought or could have been brought in two earlier suits over the same easements. The court also granted the Borough’s motions for summary judgment or judgment on the pleadings on the property owners’ claims involving the validity of construction permits, redactions in public records, and whether the Borough had acquired a recent easement through the appropriate process. One claim remained to be tried: whether the Borough violated the property owners’ due process rights by towing their truck from the disputed roadway. The court found in favor of the Borough on this claim and awarded the Borough enhanced attorney’s fees, finding that the property owners had pursued their claims vexatiously and in bad faith. The property owners appealed. The Alaska Supreme Court concluded the superior court correctly applied the law and did not clearly err in its findings of fact. Therefore, the superior court’s judgment was affirmed. View "Windel v Matanuska-Susitna Borough" on Justia Law

Property owners sued the Matanuska-Susitna Borough, challenging the validity of easements that crossed their property to give access to neighboring residences. The superior court dismissed most of the property owners’ claims on res judicata grounds, reasoning that the claims had been brought or could have been brought in two earlier suits over the same easements. The court also granted the Borough’s motions for summary judgment or judgment on the pleadings on the property owners’ claims involving the validity of construction permits, redactions in public records, and whether the Borough had acquired a recent easement through the appropriate process. However, one claim remained: whether the Borough violated the property owners’ due process rights by towing their truck from the disputed roadway. The court found in favor of the Borough on this claim, and awarded the Borough enhanced attorney’s fees, finding that the property owners had pursued their claims vexatiously and in bad faith. The property owners appealed. After review, the Alaska Supreme Court found no reversible error and affirmed the superior court, View "Windel v Matanuska-Susitna Borough" on Justia Law

A man’s condominium unit had the only access to a crawl space containing water pipes that served several other units. The condominium association’s president and a maintenance man entered the unit twice, with the owner’s permission, to address water-related maintenance issues in the crawl space, where they identified what they thought were serious problems of leaking and mold. But the unit owner denied their further requests for access to deal with these problems. The association brought suit against the unit owner, alleging that he had caused damage by concealing the leaking in the crawl space and making his own negligent repairs; it also asked for a declaratory judgment concerning its right of entry. The superior court, after an evidentiary hearing, granted a preliminary injunction allowing further inspections. After those inspections revealed that repairs were not needed after all, the association dropped its negligence claim. But it moved for summary judgment on its request for declaratory relief, which the superior court granted, deciding that the association’s declaration allowed reasonable entry for purposes of inspection and repair. The unit owner appealed. The Alaska Supreme Court concluded the superior court did not abuse its discretion in issuing the preliminary injunction or err in granting summary judgment on the claim for declaratory relief. Nor did the Court find any abuse of discretion in the superior court’s procedural rulings or its award of attorney’s fees to the association. View "Randle v. Bay Watch Condominium Association" on Justia Law