Justia Alaska Supreme Court Opinion Summaries

An elementary school nurse who unsuccessfully attempted to save the life of a choking child sought workers’ compensation benefits for mental health problems she attributed to the incident. She argued that she suffered post-traumatic stress disorder (PTSD) due to exposure to the child’s bodily fluids and resulting risk of disease and to the mental stress of the incident. The Alaska Workers’ Compensation Board denied her claims, concluding that her exposure to bodily fluids was not a sufficient physical injury to trigger a presumption of compensability and that the mental stress of the incident was not sufficiently extraordinary or unusual to merit compensation. The Board was most persuaded by the opinion of the employer’s medical expert that the nurse’s mental health problems were the result of a pre-existing mental health condition and were not caused by the incident. The Alaska Workers’ Compensation Appeals Commission affirmed. After review, the Alaska Supreme Court found: (1) the Board failed to recognize the link between exposure to bodily fluids and mental distress over the risk of serious disease, which under Alaska precedent was enough to establish a presumption that the mental distress is compensable; and (2) the Board failed to consider the particular details of the child’s death and the nurse’s involvement when it concluded as a general matter that the stress of responding to a choking incident at school was not sufficiently extraordinary to merit compensation for mental injury. However, because the Board found in the alternative that the incident was not the cause of the nurse’s mental health problems, and because both the Commission and the Alaska Supreme Court had to respect the Board’s credibility determinations and the weight it gave conflicting evidence, the denial of benefits was affirmed. View "Patterson v. Matanuska-Susitna Borough School District" on Justia Law

A landlord leased a commercial building to two tenants who operated an automotive repair business on the property. The landlord refused to adhere to provisions in the lease requiring him to maintain and repair the property and to cover the property insurance, so the tenants paid for the property insurance and for substantial repairs that were needed after the roof failed. The landlord initiated a forcible entry and detainer action after the tenants held over at the end of the lease term; the tenants counterclaimed for breach of contract. After trial, the superior court ruled that the landlord had breached the lease and awarded the tenants damages. The superior court also awarded the tenants attorney’s fees. The landlord appealed, arguing: (1) the tenants did not file their counterclaim within the applicable statute of limitations; (2) the evidence did not support the damages award; and (3) the attorney’s fees award was an abuse of discretion. Seeing no error, the Alaska Supreme Court affirmed the superior court’s decisions. View "Griffith v. Hemphill, et al." on Justia Law

Department of Corrections (DOC) officers charged a prisoner with conduct or language likely to interfere with the institution’s orderly administration and security. Following a hearing, a DOC hearing officer imposed a suspended sentence of 10 days’ punitive segregation. The prisoner appealed to the superior court, arguing that the charge was retaliatory and that he had been improperly denied the right to present in-person testimony at his hearing. The superior court rejected the prisoner’s arguments and found that DOC’s decision was supported by “some evidence,” reflecting the statutory standard of judicial review. On appeal, the prisoner argued his due process rights were violated by the hearing officer’s failure to allow in-person testimony and by DOC’s failure to include in the record on appeal a surveillance video viewed at the hearing. He also argued the superior court erred by applying the statutory “some evidence” standard of appellate review. Because the Alaska Supreme Court concluded the prisoner did not show that he was prejudiced by the lack of in-person testimony at the hearing or the surveillance video’s omission from the record on appeal, and because the superior court properly applied the statutory standard of review, judgment was affirmed. View "Nordlund v. Alaska Department of Corrections" on Justia Law

This case presented the questions of whether and how Alaska Statute 09.55.548(b) applied when the claimant’s losses were compensated by an employer’s self-funded health benefit plan governed by the federal Employee Retirement Income Security Act (ERISA). The Alaska Supreme Court concluded that an ERISA plan did not fall within the statute’s “federal program” exception. Therefore AS 09.55.548(b) required a claimant’s damages award to be reduced by the amount of compensation received from an ERISA plan. But the Supreme Court also concluded that the distinction the statute draws between different types of medical malpractice claimants was not fairly and substantially related to the statute’s purpose of ensuring claimants do not receive a double recovery — an award of damages predicated on losses that were already compensated by a collateral source. "Because insurance contracts commonly require the insured to repay the insurer using the proceeds of any tort recovery, claimants with health insurance are scarcely more likely to receive a double recovery than other malpractice claimants. The statute therefore violates the equal protection guarantee of the Alaska Constitution." View "Knolmayer, et al. v. McCollum" on Justia Law

A mother, son, and daughter conveyed real property among themselves by competing deeds. The daughter used the property as security for two bank loans and defaulted on the second one; when the bank attempted foreclosure, the son, claiming to be the property’s owner, brought suit against the bank on a constructive notice theory, also alleging that the daughter’s deed to the property was void because of fraud. The superior court found that the bank lacked notice of the son’s alleged adverse interest and granted it summary judgment as a bona fide lender. The court also dismissed the fraud claim. The son appealed. After review, the Alaska Supreme Court affirmed the grant of summary judgment on the bank’s bona fide lender status, but remanded for a determination of whether the daughter acquired her deed as a result of fraud in the factum, which, if proven, would render her title and the bank’s mortgage interest void. View "Eriksson v. Eriksson Sibley et al." on Justia Law

The Alaska Department of Corrections’s Parole Board denied inmate Donald McDonald’s discretionary parole application; he subsequently sought injunctive relief against the Department, the Board, and the Department’s then-commissioner (collectively DOC). The McDonald asked a superior court to return his parole application to the Board with instructions that the Board consider applicable factors and support its conclusions with substantial evidence. Concluding that McDonald should have brought a post-conviction relief application rather than a civil suit, the court granted a motion to dismiss. Because the McDonald's claim was a post-conviction relief claim, the Alaska Supreme Court affirmed the court’s decision. But it noted that the appropriate action would have been for the court to convert the lawsuit to a post-conviction relief application. View "McDonald v. Alaska Department of Corrections, et al." on Justia Law

In 2020 Alaska voters approved, by a slim margin, a ballot initiative that made sweeping changes to Alaska’s system of elections. The changes included replacing the system of political party primary elections with a nonpartisan primary election and adopting ranked-choice voting for the general election. A coalition of politically active voters and a political party filed suit, arguing that these changes violated the Alaska Constitution. The superior court ruled otherwise. The Alaska Supreme Court considered the appeal on an expedited basis and affirmed the superior court’s judgment in a brief order. The Court concluded the challengers did not carry their burden to show that the Alaska Constitution prohibited the election system Alaska voters have chosen. The Court published its opinion to explain its reasoning. View "Kohlhaas, et al. v.Alaska, Division of Elections, et al." on Justia Law

Two tribes claimed to be a child’s tribe for purposes of the Indian Child Welfare Act (ICWA): The Native Village of Wales claimed the child was a tribal member; the Native Village of Chignik Lagoon claims that the child is “eligible for tribal membership.” After the superior court terminated the biological parents’ parental rights, Wales moved to transfer subsequent proceedings, including potential adoption, to its tribal court. Chignik Lagoon intervened in the child in need of aid (CINA) case, arguing that the child was not a member of Wales under Wales’s constitution and that transfer of further proceedings to the Wales tribal court was not authorized under ICWA. The superior court found that the child was a member of Wales and that Wales was the child’s tribe for ICWA purposes, and therefore granted the transfer of jurisdiction. Chignik Lagoon appealed. After review, the Alaska Supreme Court affirmed the superior court’s determination that the child was a member of Wales and that Wales was appropriately designated as the child’s tribe for ICWA purposes. The Supreme Court also concluded that, given that ruling, Chignik Lagoon lacked standing to challenge the transfer of proceedings to the Wales tribal court. View "Native Village of Chignik Lagoon v. Alaska Dept. of Health & Soc. Svcs." on Justia Law

A woman filed a petition to terminate the parental rights of the father of her child because the child was conceived as a result of sexual abuse. After years of litigation, including a previous appeal, the superior court held a hearing on the petition and denied it. The woman appealed. "The court’s factual findings are supported by the record, and we do 'not re-weigh evidence when the record provides clear support for the trial court’s ruling.'" Accordingly, the Alaska Supreme Court affirmed the superior court’s denial of her petition. View "Angelica C. v. Jonathan C." on Justia Law

A couple separated after three years of marriage. They had a son who was later diagnosed with several mental disabilities. The father paid child support until the son turned 19; when the son was in his twenties the father filed for divorce. The superior court entered a divorce decree and ordered the father to pay post-majority child support, finding that the son was unable to support himself by reason of his disability. The father appealed, arguing that the superior court lacked jurisdiction and the statutory authority to order post-majority support and that the court abused its discretion by ordering him to pay the entirety of the son’s living expenses. The Alaska Supreme Court affirmed the superior court’s exercise of jurisdiction and authority to issue the support order. However, because of an inconsistency in the support order’s application, the case was remanded to the superior court for reconsideration of whether the father’s support obligation — 100% of the son’s living expenses — represented a fair percentage. View "Daum v. Daum" on Justia Law