Justia Alaska Supreme Court Opinion Summaries

In two cases consolidated by the Supreme Court for this opinion, the Alaska Workers' Compensation Appeals Commission applied different standards to evaluate motions to stay future medical benefits, and the losing party in each case petitioned for review of the Commission's stay decision. The Court granted review to decide what standard applies to stays of future medical benefits. After review, the Court held that to stay future medical benefits, the employer must show the existence of the probability that the appeal will be decided adversely to the compensation recipient. View "Municipality of Anchorage v. Adamson" on Justia Law

The issue presented to the Supreme Court in this case involved a dispute over the disposition of a deceased Alaska attorney's interest in attorney's fees from his participation, through a joint venture, in the Exxon Valdez oil spill litigation. The attorney's sister, individually and on behalf of their mother's trust, asserted claims to the attorney's fees, and the attorney's estate opposed those claims. The parties settled the dispute by agreeing that the right to attorney's fees was an estate asset, and the settlement was approved by the Alaska superior court in the deceased attorney's probate proceedings. The attorney's fees were ultimately paid to the joint venture. Both the estate and the sister then sought the deceased attorney's interest in the joint venture's attorney's fees. The estate requested that the superior court enjoin the sister's claims as violations of the settlement agreement. Around this time, the joint venture deposited what it calculated as the deceased attorney's share of the joint venture's attorney's fees in a federal interpleader action in California. The superior court ruled that under the settlement agreement, as between the estate, the sister, and the mother's trust, the estate had the right to the deceased attorney's share of the attorney's fees held by the joint venture. The superior court therefore enjoined the sister from pursuing claims to the deceased attorney's share of the joint venture's attorney's fees. The superior court later modified the injunction to allow the sister's participation in the federal interpleader action. The sister appeals, arguing that the superior court exceeded its jurisdiction, issued its judgment without proper procedures, improperly interpreted the settlement agreement, prohibited her from pursuing contract claims against third parties, and entered a vague and ambiguous judgment. She also argues that the superior court's ruling was improperly expanded to allow her participation in the federal interpleader action. Because the Supreme Court concluded that the superior court acted within its jurisdiction, followed adequate procedures, did not prevent the sister from pursuing her individual contract claims against the joint venture, was not vague and ambiguous in its ruling, and did not expand the ruling's substance when modifying it, the Court affirmed the superior court's orders and judgment. View "Dimeff v. Estate of Robert Merle Cowan" on Justia Law

Appellant Clinton DesJarlais filed an application with the Office of the Lieutenant Governor seeking certification of an initiative that would generally prohibit abortion. The lieutenant governor, acting on the advice of the Department of Law, concluded that the initiative was unconstitutional and declined to certify it for circulation. Appellant filed suit against the State in superior court challenging the lieutenant governor's decision. The superior court granted summary judgment in favor of the State and appellant appealed. Because appellant's proposed initiative was clearly unconstitutional under controlling United States Supreme Court precedent, the Alaska Supreme Court affirmed the superior court's grant of summary judgment. View "DesJarlais v. Alaska" on Justia Law

Following a car accident with an uninsured motorist, Lori McDonnell filed suit against her insurer State Farm Mutual Automobile Insurance Company on behalf of herself and her minor son, Luke. McDonnell sought a declaratory judgment that: (1) she was entitled to have her personal injury claims settled by appraisal under the mandatory appraisal statute; and (2) a provision in her State Farm insurance policies requiring her to file suit against the insurance company within two years of the accident was void as against public policy. The superior court ruled that the mandatory appraisal statute did not apply to personal injury claims. The court further ruled that the contractual two-year limitations provision was enforceable, but only if State Farm could show that it was prejudiced by an insured's delay in bringing suit, and that the appropriate accrual date for the limitations period was the date State Farm denied an insured’s claim, rather than the date of the accident. McDonnell and State Farm both appealed that decision. Finding no error in the trial court's decision, the Supreme Court affirmed. View "McDonnell v. State Farm Mutual Automobile Ins. Co." on Justia Law

The question before the Supreme Court in this appeal was whether a defendant who pled no contest to disorderly conduct in a criminal action could be collaterally estopped from relitigating the elements of that crime in a related civil declaratory judgment action regarding insurance coverage, thereby precluding coverage. Kent Bearden pled no contest to disorderly conduct for punching Paul Rasmussen. Rasmussen subsequently filed a civil complaint against Bearden, and Bearden tendered the lawsuit to State Farm Insurance Company to defend and indemnify him under his homeowners insurance policy. State Farm sought declaratory relief and moved for summary judgment on the ground that Bearden's conduct could not be considered an "accident" within the meaning of the insurance policy because his no-contest plea collaterally estopped him from relitigating the issues of mens rea and self-defense. The superior court granted the motion. Finding no error with the superior court's decision, the Supreme Court affirmed. View "Bearden v. State Farm Fire & Casualty Co." on Justia Law

Appellee Tamarack Air, Ltd. negligently damaged Appellant James Madonna's airplane while it was on Tamarack's airfield after it had been in Tamarack's shop for maintenance. Tamarack offered to fix the plane, but Madonna refused the offer. Instead, he elected to ship the plane to Wyoming and had the plane repaired at the original factory. Tamarack argued that Madonna had failed to mitigate his damages and refused to compensate Madonna for the full cost of these repairs. A jury awarded Madonna most, but not all, of the cost of having the plane repaired out of state. On appeal, Madonna argued that the trial court erred by refusing to let him present several other claims for damages related to the accident. But finding no error, the Supreme Court affirmed the trial court in all respects. View "Madonna v. Tamarack Air, Ltd." on Justia Law

A motorcyclist was involved in a single-vehicle accident resulting in a cut on his head and minor damage to his motorcycle. The accident involved no other drivers, vehicles, or property. Because the motorcycle was not insured at the time of the accident, the Division of Motor Vehicles (DMV) suspended the driver's license. The motorcyclist appealed the suspension to the superior court, arguing that the suspension violated his equal protection and due process rights under the Alaska Constitution and was precluded by the de minimis nature of the accident. The superior court rejected the his arguments and awarded attorney's fees to DMV. The motorcyclist appealed to the Supreme Court, raising the same substantive arguments and challenging the award of attorney's fees. Upon review, the Court concluded that the motorcyclist's constitutional and common law arguments did not compel reversal of the administrative suspension. However, the Court vacated the entry of attorney's fees and remanded the case to the superior court to determine how the motorcyclist's constitutional challenges should have impacted the award. View "Titus v. Alaska Dept. of Admin., Div. of Motor Vehicles" on Justia Law

John Doe A and John Doe B were convicted of criminal offenses that required them to register and comply with Alaska’s Sex Offender Registration Act (ASORA). After their convictions, the legislature amended ASORA, requiring certain offenders to comply with additional registration requirements. The John Does sued, claiming that retroactive application of ASORA’s amendments to them violated the Ex Post Facto Clause of the Alaska Constitution. The superior court agreed, and the State appealed. In 2008 the Supreme Court decided "Doe v. State" (Doe I), holding that ASORA’s amendments violated the Ex Post Facto Clause and did not apply to persons who committed their crimes before the amendments became effective. Two years later the Court promulgated Alaska Appellate Rule 106, which provided that any issue decided by a two-to-one vote shall not have precedential effect. When the COurt promulgated Appellate Rule 106 it was silent on the question whether that rule might have retroactive effect. The Court held in this case that its two-to-one decision in Doe I was binding precedent that controlled the outcome of this case because Appellate Rule 106 did not have retroactive application. View "Alaska v. Doe" on Justia Law

This case involved a three-way transfer of boat tie-up spaces in a recreational subdivision. The principal issue before the Supreme Court was whether the trial court erred in requiring the joinder of one of the people involved in the transfer as an indispensable party. Upon review, the Court concluded that the trial court did not err because appropriate relief could not be afforded in the absence of the person in question. The Supreme Court also concluded that the case was properly dismissed because the plaintiff refused to comply with the court's order requiring joinder. View "Weilbacher v. Ring" on Justia Law

Dixie Dixon was injured in an automobile accident when a car driven by Joshua Paul Blackwell ran a red light. She sued and received a verdict that was lower than Blackwell's Alaska Civil Rule 68 offer of judgment. On appeal she challenged the adequacy of the verdict and the efficacy of the offer of judgment. Because the jury's verdict was not inadequate, the offer Blackwell made was a valid Rule 68 offer, and the judgment finally rendered by the court was at least five percent less favorable to Dixon than the offer, the Supreme Court affirmed the superior court's judgment. View "Dixon v. Blackwell" on Justia Law