Justia Alaska Supreme Court Opinion Summaries

A cannery worker reported two injuries: one to his back and one to his shoulder. He suffered these injuries at different times but while working for the same employer. The employer paid some medical benefits for both injuries but eventually challenged its obligation to provide further care. The Alaska Workers’ Compensation Board denied the worker’s claim for more medical benefits, and the Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision. The worker appealed pro se. The Alaska Supreme Court concluded the Commission properly affirmed the Board’s decision as to the back injury, but that the Board’s findings as to the shoulder injury lacked adequate support in the record. The Commission’s decision was therefore reversed in part and remanded for further proceedings. View "Espindola v. Peter Pan Seafoods, Inc." on Justia Law

An Alaskan superior court denied a father’s motion to modify a foreign court’s custody determination because it did not believe it had subject matter jurisdiction to modify the order under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The father appealed, arguing the superior court erred when it held that it did not have jurisdiction. Because the superior court correctly determined that it lacked jurisdiction to modify the custody order, the Alaska Supreme Court affirmed. View "Christensen v. Seckin" on Justia Law

In 2019, an attorney representing Vern H. in an unrelated matter petitioned the superior court for an order authorizing Vern’s hospitalization for a mental health evaluation. The attorney indicated that Vern said he needed to go to a behavioral health unit and threatened to hang himself. The attorney believed Vern was mentally ill and likely to cause harm to himself. After three days in jail, Vern contended he no longer met the criteria for involuntary detention, or should have been re-evaluated to determine whether continued detention was warranted, or if a less restrictive environment could have met his needs. This appeal raised two questions about involuntarily detaining an individual in jail pending transport to a hospital for a civil commitment mental health evaluation: (1) when transport is not immediately available and the individual requests a review hearing, what standard of proof applies to the individual’s continued detention; and (2) is the State required to show, by clear and convincing evidence, that jail is the least restrictive alternative available for the detention? The Alaska Supreme Court held that the probable cause standard applied to review hearings regarding an individual’s continued detention, and that the State must prove detention in jail is the least restrictive alternative available while an individual awaits transport to a hospital for evaluation. View "In the Matter of the Necessity for the Hospitalization of Vern H." on Justia Law

A national political organization engaged an Alaska media consultant to reserve over $1 million worth of television advertising time prior to the 2018 gubernatorial primary race. The national organization did not register with the Alaska Public Office Commission, and did not report the reservations to the agency. The Commission concluded that this conduct violated a statute requiring all entities to register before making any “expenditures,” including promises or agreements to transfer something of value, to influence an election. The superior court affirmed the Commission’s decision on appeal. The national organization appealed to the Alaska Supreme Court, arguing that the Commission defined “expenditures” too broadly. The Supreme Court concluded the Commission reasonably interpreted the campaign finance statute to include agreements to purchase television advertising, even when these agreements were not legally binding. The Court therefore affirmed the superior court’s decision affirming the Commission’s order. View "Republican Governors Association v. Alaska Public Offices Commission" on Justia Law

After the Department of Corrections (DOC) investigated an allegation that a probation officer was providing special treatment in return for sexual favors and found it to be unsubstantiated, the probation officer sought the investigation records. DOC denied his request and the probation officer appealed to the superior court, which reversed the denial and ordered the records released because the allegation had not been substantiated. DOC appealed. The Alaska Supreme Court reversed the superior court’s order because the records were shielded from disclosure by the invasion of privacy exemption to the Public Records Act. View "Alaska Department of Corrections v. Porche" on Justia Law

A husband and wife sued medical care providers after the wife suffered a seizure, allegedly due to a doctor’s decision to abruptly discontinue her medication. The superior court granted summary judgment to the medical care providers, ruling that the couple’s only expert witness, a pharmacist, was unqualified to provide testimony about the matter at issue because he was not a doctor of internal medicine and was not board-certified in the doctor’s field or specialty. The couple appealed. After review, the Alaska Supreme Court concurred with the trial court that the pharmacist’s testimony was not sufficient to create a genuine issue of material fact about the relevant standard of care. The Court therefore affirmed the grant of summary judgment to the health care providers. View "Beistline v. Footit, and Banner Health Inc., D/B/A Fairbanks Memorial Hospital" on Justia Law

Two defendants in a wrongful death suit settled with the decedent’s estate, resulting in a recovery for her minor child’s benefit. The estate’s attorney received payment from the settlement, but the remaining funds were reserved against potential fee awards to the remaining defendants should they prevail in the ongoing litigation. The estate appealed, arguing the remainder of the funds should have been immediately disbursed for the child’s benefit. The non-settling defendants cross-appealed, arguing that the entire settlement fund should have been reserved for their recoverable costs and fees. Because the prevailing defendants would have no other source from which to recover expenses, the Alaska Supreme Court affirmed the superior court’s reservation of settlement funds. But because the Supreme Court construed the common fund doctrine to apply, it also affirmed the court’s distribution of the estate’s attorney’s fees and costs. View "Doan v. Banner Health Inc., et al." on Justia Law

The employee of a subcontractor on a state public works project sued the prime contractor’s surety bond for unpaid labor under Alaska’s Little Miller Act. The trial court ruled the employee failed to give notice to the contractor within the statutorily required 90 days of his last date of labor on the project. The trial court entered a directed verdict against the employee. The employee appealed to the superior court, which denied the appeal, and then petitioned the Alaska Supreme Court for hearing. This case presented two issues of first impression: (1) how to define “labor;” and (2) whether “notice” was effective on the date of mailing or the date of receipt. Under the Little Miller Act, the Supreme Court defined “labor” as work that was “necessary to and forwards” the project secured by the payment bond, and held the effective date of “notice” to be the date notice is sent via registered mail. The superior court judgment denying the employee's appeal was reversed and the matter remanded for further proceedings. View "Dat Luong DBA LVDH Construction v. Western Surety Co." on Justia Law

A federal district court certified two questions of law to the Alaska Supreme Court. Schlumberger Technology Corporation was a Texas corporation providing technology services to the oil and gas industry in Alaska. Travis Buntin worked for Schlumberger in Alaska until early 2016. Shortly thereafter Buntin sued Schlumberger in federal court alleging, among other things, failure to pay overtime compensation in violation of the Alaska Wage and Hour Act (AWHA). Schlumberger responded that Buntin was not entitled to overtime compensation because the AWHA exempts individuals employed “in a bona fide executive, administrative, or professional capacity” from overtime payment. Responding to the federal court's questions, the Alaska Supreme Court concluded that an employer had to prove that an AWHA exemption applied by a preponderance of the evidence, and reversed precedent to the contrary. The Supreme Court also concluded that the interpretive principle in Encino Motorcars v. Navarro, 138 S. Ct. 1134 (2018) that courts must give federal Fair Labor Standards Act (FLSA) exemptions a fair interpretation applied when the AWHA text explicitly requires alignment with FLSA interpretations. View "Buntin v. Schlumberger Technology Corporation" on Justia Law

An Alaska State Commission for Human Rights (State) employee with preexisting medical conditions was involved in a work-related motor vehicle accident in January 2017. The employee consulted with Dr. Teresa Bormann two days after the accident; Dr. Bormann referred the employee to chiropractic treatment. After several month of treatment, Dr. Bormann referred the employee to physical therapy at United Physical Therapy (UPT) for chronic neck pain and headache. After an evaluation UPT recommended eight weeks of twice weekly physical therapy. Dr. Bormann endorsed the treatment plan, and the employee’s symptoms improved enough that she reduced her physical therapy visits to once a week beginning in mid-January. She saw UPT three times in February 2018. Payment for these February visits became the main dispute before the Board. The State arranged an employer’s medical evaluation (EME) with a neurologist and an orthopedist. The EME doctors diagnosed the employee with a cervical strain caused by the accident as well as several conditions they considered preexisting or unrelated to the work injury. After the State filed a retroactive controversion of medical treatment, the employee’s healthcare provider filed a workers’ compensation claim seeking payment for services it provided before the controversion was filed. The State disputed its liability for payment, and after several prehearing conferences, the Alaska Workers’ Compensation Board set a hearing on the merits of the provider’s claim. The Board ordered the State to pay the provider approximately $510.00 for the services. The State appealed, disputing several procedural aspects of the decision, and the Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision. Finding no reversible error, the Alaska Supreme Court affirmed the Commission’s decision. View "Alaska, Department of Health and Social Services v. Thomas et al." on Justia Law