Justia Alaska Supreme Court Opinion Summaries

This case concerned the Office of Children’s Services' (OCS) decision to take emergency custody of a baby who tested positive for drugs at birth, and the subsequent legal proceedings that ensued. Both parents initially expressed interest in voluntarily relinquishing their parental rights, but the court found that the relinquishments were not valid because the forms were not dated or signed by an OCS witness. The foster parents opposed OCS's plan to move the baby from their home to her maternal aunt’s home and were granted permission to intervene for a placement review hearing. After the hearing, the court concluded that OCS had abused its discretion in deciding to move the child and granted the mother's motion to withdraw her putative relinquishment. The foster parents then filed a motion to reconsider the order allowing the mother to withdraw her relinquishment. The court granted the foster parents’ motion and reversed its order withdrawing the relinquishment. The court then terminated the parental rights of both parents without holding an evidentiary hearing. OCS and both parents appealed the superior court’s decisions. The Supreme Court of the State of Alaska held that it was error to allow the foster parents’ continued intervention, to reinstate the relinquishments, and to terminate parental rights. The court vacated all the orders relating to those errors and remanded the case to the superior court for further proceedings. The court clarified that it was an abuse of discretion to permit the foster parents to continue to intervene regarding the validity of the parents’ relinquishments, to revisit the validity of the relinquishments, and to issue termination orders without providing the parties with notice and an opportunity to be heard, as well as a legal error to issue a termination order without making a best interests finding. View "Tara R. v. State of Alaska" on Justia Law

In this case, the Sitka Tribe of Alaska challenged the State of Alaska's management of a commercial fishery, arguing that it harmed a subsistence fishery. The tribe argued that the state violated the subsistence priority statute and the common use and sustained yield clauses in the Alaska Constitution. The tribe also claimed that the state was misinterpreting a regulation controlling the fishery and sought a preliminary injunction to prevent the state from managing the fishery according to that interpretation during the upcoming season. The superior court denied the preliminary injunction.The tribe eventually won on its statutory and regulatory claim, but the superior court denied its constitutional claim and its request for attorney’s fees. The tribe appealed to the Supreme Court of Alaska.The Supreme Court of Alaska affirmed the superior court’s decisions. It held that the hard look doctrine, requiring agencies to consider all relevant information, already existed and there was no need to create a constitutional requirement not in the plain language of Article VIII, Section 4 of the Alaska Constitution. The court also declined to review the tribe’s motion for a preliminary injunction under the public interest exception, as the issue was moot and did not justify application of the public interest exception. Lastly, the court held that the superior court did not abuse its discretion by declining to award attorney’s fees as the tribe had not shown that the superior court's decision was arbitrary, capricious, manifestly unreasonable, or stemmed from an improper motive. View "Sitka Tribe of Alaska v. State of Alaska" on Justia Law

In the Supreme Court of the State of Alaska, the case involved a self-represented prisoner who sued the Department of Corrections (DOC) for intentional and negligent infliction of emotional distress. The prisoner alleged that DOC held him in administrative segregation (solitary confinement) for 504 days and that corrections officers denied him any meaningful opportunity to appeal or be heard regarding his segregation. The prisoner contended that the corrections officers’ actions amounted to extreme and outrageous conduct that caused him severe emotional distress. The superior court granted summary judgment in favor of DOC, reasoning that DOC’s conduct was not extreme and outrageous and that the prisoner’s distress was not severe enough to give rise to liability.On appeal, the Supreme Court of the State of Alaska concluded that the superior court abused its discretion in dismissing the prisoner's claim of intentional infliction of emotional distress. The Supreme Court reversed the superior court’s grant of summary judgment in DOC’s favor as to the prisoner’s intentional infliction of emotional distress claim. The Supreme Court also vacated the superior court’s order approving the attorney general’s certification that individual corrections officers acted within the scope of their employment, reversed the court’s denial of the prisoner’s request to compel certain discovery, and remanded for further proceedings consistent with this decision. However, the Supreme Court affirmed the superior court’s grant of summary judgment with respect to the prisoner’s negligent infliction of emotional distress claim. View "Watkinson v. State of Alaska" on Justia Law

In a case before the Supreme Court of the State of Alaska, the court was asked to determine the deadline for filing a claim against a decedent’s estate for reimbursement for Medicaid services provided to the decedent while alive. The probate code of Alaska provides that for claims arising “before the death of the decedent,” the creditor must file within four months after the estate's representative first published notice to creditors. For claims arising “at or after the death of the decedent,” the creditor must file within four months after the claim arose. The court held that Medicaid estate recovery claims arise before death and therefore must be filed within four months after notice to creditors. The court reasoned that although the state may not pursue these claims until after the Medicaid beneficiary has died, these claims arise when Medicaid services are provided, not when the claims become enforceable. The court's decision was based on the interpretation of the probate code, the underlying legislative purpose of the Medicaid estate recovery statute, and the weight of precedent from other jurisdictions. View "In the Matter of the Estate of Fe Perez Abad" on Justia Law

In this case, the Supreme Court of the State of Alaska dealt with an appeal against the termination of parental rights of two parents, Elena F. and Ronan F., by the State of Alaska, Department of Family & Community Services, Office of Children’s Services. The Office of Children’s Services (OCS) had removed the two Indian children from their parents' home due to reported domestic violence and later terminated both parents' rights after two years. The parents appealed, arguing that OCS failed to make active efforts to reunify the family.The court found that the OCS made active efforts to reunify Elena with her children even in light of her serious mental illness, substance abuse, and her increasingly violent threats and behavior. As such, the court affirmed the termination of Elena's parental rights.However, the court found that the OCS did not make active efforts to reunify Ronan with his children. The court noted that there was no evidence that two out of three caseworkers assigned to Ronan made any efforts toward his reunification with his children. Therefore, the court reversed the termination of Ronan's parental rights. View "Ronan F. v. State of Alaska" on Justia Law

In this case, the Supreme Court of the State of Alaska reversed the Superior Court's decision and held that the Department of Corrections' policy change regarding the definition of "firm release date" for prisoners was a regulation that required compliance with the rulemaking procedures of the Administrative Procedures Act (APA). The Department of Corrections had changed its interpretation of "firm release date" twice. Initially, a prisoner's release date on discretionary parole was not considered a "firm release date." In 2016, the Department changed this interpretation and considered a discretionary parole release date as a "firm release date." However, in 2019, the Department reverted to its initial interpretation. The plaintiff, Trevor Stefano, a prisoner, argued that this change in policy violated the APA because it amounted to revising a regulation without going through the APA’s rulemaking process. The Supreme Court agreed with Stefano, noting that the Department's actions were a changed interpretation of existing regulation that had to be adopted through rulemaking. Because the Department did not follow the rulemaking procedure, the Court reversed the Superior Court's decision and remanded the case for further proceedings. View "Stefano v. State of Alaska, Department of Corrections" on Justia Law

In this case in the Supreme Court of the State of Alaska, a candidate who narrowly lost an election brought a case alleging that the Division of Elections had improperly allowed some voters to cast ballots without meeting constitutional and statutory residency requirements. The court upheld the election results in favor of the opposing candidate and dismissed the losing candidate's lawsuit. The winning candidate then moved for attorney’s fees and costs, asserting that certain claims made in the election contest were frivolous or made in bad faith. The court agreed and awarded the winning candidate full attorney’s fees and costs related to those claims. The losing candidate appealed, arguing that he was protected from an adverse attorney’s fees award as a constitutional claimant and that the court failed to follow proper procedure for imposing fees and costs as sanctions. The Alaska Supreme Court held that the unsuccessful candidate’s constitutional claims were not frivolous or made in bad faith and reversed the award of attorney’s fees and costs. However, the court ruled that the unsuccessful candidate is not exempt from sanctions for violating court rules after notice and an opportunity to be heard and remanded for further proceedings to determine whether sanctions could be awarded for violations of court rules. View "Pruitt v. State of Alaska, Division of Elections" on Justia Law

The Supreme Court of the State of Alaska reviewed challenges to a redistricting plan adopted by the Alaska Redistricting Board. After the 2020 census, the Board adopted a plan for 40 House of Representative districts and 20 Senate districts. Several entities filed challenges to this plan, arguing that certain districts were unconstitutional due to violations of due process and gerrymandering. The superior court found two House districts and one Senate district to be unconstitutional and directed the Board to undertake further redistricting efforts. Four petitions for review were filed with the Supreme Court.The Court affirmed the superior court's ruling regarding the Senate district, but reversed the ruling regarding the two House districts. The Court found that the Board did not violate the "hard look" requirement, which requires that the Board seriously consider all salient problems and engage in reasoned decision-making. The Court also held that the Board sufficiently complied with the Hickel process, a procedural sequence that ensures the redistricting satisfies federal law without unnecessarily compromising the Alaska Constitution.Furthermore, the Court determined that the Board did not have discriminatory intent in its actions, and that the minor deviations in population among various districts did not violate the "one person, one vote" requirement. The Court also concluded that the Board did not violate the provision requiring each House district to contain a population as near as practicable to the quotient obtained by dividing the population of the state by forty.Regarding the Senate district, the Court affirmed the superior court’s conclusion that the relevant Senate district pairings were an unconstitutional gerrymander. The Court remanded the case for further redistricting efforts consistent with its order. View "In the Matter of the 2021 Redistricting Cases" on Justia Law

The Supreme Court of the State of Alaska was asked to determine whether the question of a deceased worker's status as an employee or independent contractor under the Alaska Worker's Compensation Act should be determined by a jury or a judge. The lawsuit was initiated by the estate of Nicholson Tinker, a worker who was killed in a construction accident while working for Mark Welty, doing business as North Country Services. Welty had no workers' compensation coverage at the time of the accident. Tinker's estate argued that he was an employee and that under the Act, Welty was presumed negligent because he had no compensation coverage. Welty argued that Tinker was an independent contractor, hence the Act did not apply.The superior court decided that the question of employee status was an issue for the jury to decide. The estate appealed this decision, arguing that the Supreme Court's earlier decision in Benson v. City of Nenana determined that a judge, not a jury, should decide the issue of a worker's status under the Act.The Supreme Court of the State of Alaska agreed with the estate, holding that the superior court must determine whether Tinker was an employee or independent contractor under the Act as a preliminary issue before trial. The Court reasoned that the applicability of the Act is a legal determination with factual underpinnings that the court should decide as a preliminary matter. The Court also noted that determining the employee status promptly is significant due to its potential impact on basic issues such as the type of action a party can bring or the burden of proof for negligence. Therefore, the Court reversed the superior court’s order that the jury decides the issue of employee status and remanded for further proceedings. View "Leona Seal, Personal Representative of the Estate of Nicholson J. Tinker v. Mark C. Welty D/B/A North Country Services" on Justia Law

The Supreme Court of the State of Alaska ruled that the extended pre-evaluation detentions of two individuals, Abigail B. and Jethro S., violated their substantive due process rights. Both individuals were detained at local hospitals after suffering psychiatric emergencies. Court orders authorized immediate transportation of each individual to an available bed at an evaluation facility for further examination. However, due to a lack of available beds, neither individual was immediately transported, resulting in prolonged detentions. Abigail B. was detained for 13 days before transportation for evaluation, while Jethro S. was detained for 17 days. Both individuals appealed the detention orders, arguing that their prolonged detentions violated their substantive due process rights. The court agreed, citing a recent decision (In re Hospitalization of Mabel B.) that stated pre-evaluation detentions must bear a reasonable relation to the purpose of facilitating immediate transportation for evaluation. The court concluded that the nature and duration of Abigail's and Jethro's detentions were not reasonably related to their purpose, thereby violating their substantive due process rights. View "In the Matter of the Necessity for the Hospitalization of: Abigail B." on Justia Law