Justia Alaska Supreme Court Opinion Summaries

A couple divorced, and the superior court awarded them joint legal custody of their minor child, with primary physical custody to the mother. The court also divided the couple’s marital estate. The father, representing himself, appealed, arguing that the division of the marital estate was inequitable. He claimed errors in the court’s determinations, including not crediting him for post-separation payments, not allowing him to apply for the child’s Permanent Fund Dividend (PFD), not allowing him to claim the child as a dependent for tax purposes, and its custody decision.The superior court held a one-day trial by videoconference, where both parties testified. The court issued a decree of divorce and findings of fact and conclusions of law, awarding joint legal custody to both parties and primary physical custody to the mother. The court divided the proceeds from the sale of the marital home, taking into account the father’s child support arrearage and an escrow shortage. The court also divided the couple’s vehicles and assigned debts based on testimony and the mother’s spreadsheet. The court ordered that the mother would be responsible for the child’s PFD and could claim the child as a dependent for tax purposes. The court ordered that the father’s 401(k) be divided equitably according to the mother’s spreadsheet.The Supreme Court of the State of Alaska reviewed the case. It vacated the superior court’s division of the marital estate, finding that the court’s treatment of the father’s 401(k) was unclear and lacked clarifying findings. It also found legal error in the court’s failure to address post-separation payments when dividing the marital estate. The court remanded for further proceedings on these issues. The Supreme Court otherwise affirmed the superior court’s decisions, including the custody award and the decisions regarding the child’s PFD and tax dependency. View "Wolffe v. Wolffe" on Justia Law

A nine-year-old boy lifted his grandmother, causing her to fall and suffer pain. The boy’s father, in response, pushed the boy to the ground to show him "how it felt to be Grandma." The boy’s mother sought a domestic violence protective order (DVPO) against the father on the boy’s behalf. The superior court granted the order, finding that the father had assaulted the boy and rejected the father's argument that the push was reasonable parental discipline.The superior court found that the father's actions amounted to an assault and were not reasonable corporal discipline. The court noted that the father should have calmed down and had a mature conversation with his son instead of pushing him to the ground. The court granted a long-term DVPO against the father. The father moved for reconsideration, arguing insufficient evidence of assault and permissible corporal discipline. The court denied reconsideration.The Supreme Court of the State of Alaska reviewed the case. The court held that there was sufficient evidence to support the superior court’s finding of assault, as the father’s actions caused the boy physical pain and were reckless. The court also affirmed the superior court’s rejection of the reasonable corporal discipline defense, finding that the father’s actions were not reasonable or appropriate and were motivated by retribution rather than a desire to promote the child’s welfare. The Supreme Court affirmed the superior court’s judgment. View "Peter R. v. B.M.R." on Justia Law

A mother and father, both residing in Nome, Alaska, disputed custody of their three children. The mother sought to modify the existing custody arrangement and move with the children to Palmer, where she and her new husband had purchased a home. The father opposed the move. Following a hearing, the superior court awarded primary physical custody and sole legal custody of the children to the father. The mother appealed.The Superior Court of the State of Alaska, Second Judicial District, found that the mother's relocation to Palmer constituted a substantial change in circumstances, necessitating a modification of the custody arrangement. The court awarded primary physical custody to the father, emphasizing the importance of maintaining the children's geographic stability in Nome. The court also awarded sole legal custody to the father, reasoning that joint legal custody only works when parents' decisions are consistent nearly all the time, which it found was not the case here.The Supreme Court of the State of Alaska reviewed the case and found that the superior court erred by not conducting the required symmetrical analysis when one parent intends to relocate a significant distance. The court also failed to consider the children's relational stability in determining physical custody. The Supreme Court held that the superior court must conduct a symmetrical analysis, considering the consequences of the move with or without the children, and must also consider relational stability, not just geographic stability. Additionally, the Supreme Court found that the superior court's award of sole legal custody to the father was unsupported by the record and based on an incorrect legal standard. The Supreme Court vacated and remanded the award of primary physical custody for the superior court to conduct the required analyses and reversed the award of sole legal custody, maintaining joint legal custody between the parents. View "Outwater v. Ahmasuk" on Justia Law

A challenge was brought against the Alaska Division of Elections for including Eric Hafner, a federal prisoner, as one of the four candidates on the 2024 general election ballot for the U.S. House of Representatives. Hafner, who finished sixth in the primary, was elevated to the general election ballot after two of the top-four candidates withdrew. The Alaska Democratic Party and Anita Thorne argued that Alaska law only allows the fifth-place candidate to replace a withdrawn candidate, not the sixth-place candidate.The Superior Court of Alaska, Third Judicial District, Anchorage, rejected the plaintiffs' claims for injunctive and declaratory relief. The court found that the plaintiffs did not demonstrate irreparable harm and sided with the Division's interpretation of the law, which required successive replacements for withdrawn candidates. The court also concluded that Hafner was not constitutionally disqualified and that he was an indispensable party to the litigation.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court's decision. The court held that AS 15.25.100(c) requires the Division to replace successive withdrawn candidates on the general election ballot if additional primary candidates are available. The court found that the statute's language and the purpose of Ballot Measure 2, which aimed to increase voter choice, supported this interpretation. The court also noted that its precedent favors resolving ambiguities in election laws in favor of greater ballot access. Thus, the judgment of the superior court was affirmed. View "Alaska Democratic Party v. Beecher" on Justia Law

The Office of Children’s Services (OCS) removed two Indian children from their home after finding their parents intoxicated and unable to care for them. The superior court adjudicated the children as being in need of aid, and the children’s tribe intervened. The children’s father moved to another state and, after initially failing to engage with OCS, eventually completed all case plan requirements. OCS then sought to place the children with their father through the Interstate Compact for the Placement of Children (ICPC), but the other state denied approval. Despite this, OCS sought permission from the superior court to release custody to the father while he was temporarily in Alaska.The superior court found that the ICPC was inapplicable to a release of custody to a parent under AS 47.14.100(p) and granted OCS’s request, dismissing the case. OCS released custody to the father before he left Alaska. The Native Village of Saint Michael appealed, arguing that the ICPC should apply and that the superior court failed to make adequate best interest findings.The Supreme Court of the State of Alaska reviewed the case and concluded that when OCS properly releases custody of a child to a parent under AS 47.14.100(p), the requirements of the ICPC do not apply, even if the parent plans to subsequently transport the child to another state. The court affirmed the superior court’s decision that the ICPC was inapplicable under the circumstances and that the other state’s approval was not required for placement with the father. The court also affirmed the dismissal of the case. View "Native Village of Saint Michael v. State" on Justia Law

A mother and father had their parental rights terminated in two consolidated child in need of aid (CINA) cases. They appealed the termination, and the Alaska Supreme Court reversed the termination order and remanded for further proceedings. While the appeal was pending, the children's foster parents petitioned to adopt them, and the superior court granted the adoption petitions. On remand, the superior court did not require the Office of Children’s Services (OCS) to make further efforts to reunify the family and instead reevaluated the same information, terminating the parental rights again. The parents appealed, and the Alaska Supreme Court reversed the termination order a second time.The parents then sought to vacate the adoption and reopen the CINA case. The adoptive parents opposed, arguing that the parents' attempt to vacate the adoption was barred by the one-year limitation period for challenging an adoption decree. The superior court agreed with the adoptive parents, concluding that the parents' failure to appeal the adoption decree itself within one year barred their challenge. The court also concluded that the motion to reopen the CINA case was moot because the adoption remained valid, and the children were no longer in need of aid.The Alaska Supreme Court reviewed the case and affirmed the superior court's judgment. The court held that the one-year limitation period for challenging an adoption decree under AS 25.23.140(b) applies strictly to appeals of the adoption decree itself, not to appeals of related termination orders in CINA cases. The court emphasized the legislative intent to provide finality and stability for adopted children, noting that allowing collateral attacks on adoption decrees beyond the one-year period would unreasonably disrupt the upbringing of adopted children. Consequently, the adoption remained valid, and the CINA case was moot. View "In re Adoption of C.R. and E.R. v. State" on Justia Law

A general contractor, Keluco General Contractors, Inc., secured a workers’ compensation and employers’ liability policy through Travelers Property Casualty Company of America. The policy was set to last one year, expiring on March 5, 2017. After the policy expired, a Keluco employee was injured at work. Keluco attempted to make a claim on its workers’ compensation policy and discovered it had expired. Travelers claimed to have sent a notice of nonrenewal to Keluco and its insurance agent, Gretchen Santerre, but Keluco claimed it never received the notice.Keluco sued Santerre and her employer, Country Mutual Insurance Company, for failing to inform it of the nonrenewal notice. Santerre filed a third-party complaint against Travelers. The Superior Court of Alaska granted partial summary judgment against Travelers, ruling that it failed to send the nonrenewal notice in the manner required by statute, specifically by not obtaining a certificate of mailing from the United States Postal Service (USPS). The court found that Travelers breached its contract with Keluco.The Supreme Court of the State of Alaska reviewed the case. The court affirmed the Superior Court’s rulings on summary judgment, agreeing that Travelers violated AS 21.36.260 by not obtaining a certificate of mailing from USPS and thus breached its contract with Keluco. The court also affirmed the dismissal of Travelers’ contribution claim against Santerre, noting that Alaska law allows for the allocation of fault to a party who has settled out of a case.However, the Supreme Court reversed the Superior Court’s determination of when prejudgment interest began to accrue. The Supreme Court held that prejudgment interest should begin to accrue on September 20, 2017, the date the Keluco employee was injured and entitled to workers’ compensation benefits, rather than January 9, 2017. The case was remanded for recalculation of prejudgment interest. View "Travelers Property Casualty Company of America v. Keluco General Contractors" on Justia Law

Three Alaska residents challenged the Division of Elections' process for certifying a ballot initiative for the November 2024 election. They claimed the Division violated regulations and statutes by allowing corrections to circulators’ certifications of petition booklets used to gather signatures. The superior court granted summary judgment to the Division and the initiative’s sponsors on this issue. After a trial on other issues, the court ordered the Division to reject some signatures and booklets but found enough valid signatures remained to keep the initiative on the ballot. The challengers appealed the summary judgment decision.The superior court ruled that Alaska Statute 15.45.130 allows corrections to circulators’ certifications after the petition is filed, as long as the corrections are made before the Division completes its signature-counting process. The court found that the statute’s language, legislative history, and intent support this interpretation, aiming to facilitate the initiative process and avoid disenfranchising voters due to technical errors.The Alaska Supreme Court reviewed the case and affirmed the superior court’s decision. The court held that AS 15.45.130 permits corrections to certifications during the Division’s 60-day review period, even after the one-year signature-gathering deadline and the start of the legislative session. The court found that the statute’s plain language, legislative history, and purpose support allowing corrections to ensure voters’ signatures are counted. The court also determined that the Division’s regulations do not prohibit post-filing corrections and that the Division’s interpretation of its regulations was reasonable. Thus, the initiative remained on the ballot. View "Crow v. Beecher" on Justia Law

A contractor hired a subcontractor to work on a remote bridge construction project. The scope of the work changed, and neither party kept detailed records of the changes and associated costs. Years after the project was completed, the subcontractor sued for damages, claiming unpaid work. The superior court found that the subcontract did not govern the extra work, awarded some damages to the subcontractor, and precluded some claims due to discovery violations. The court also found the contractor to be the prevailing party and awarded attorney’s fees. Both parties appealed.The superior court denied summary judgment motions from both parties, finding factual disputes. It precluded the subcontractor from pursuing certain damages claims due to insufficient documentation but allowed evidence for contingent findings. After a bench trial, the court awarded the subcontractor $191,443.42, later reduced to $146,693.42 upon reconsideration. The court found the contractor to be the prevailing party under Rule 68 and awarded attorney’s fees.The Supreme Court of Alaska reviewed the case. It concluded that the superior court abused its discretion by precluding the subcontractor’s claims for snowmachine use and labor without considering less severe sanctions. The court affirmed the superior court’s findings on other damages but reversed the awards for Morris Johnson’s labor and boat use, remanding for recalculation. The prevailing party determination and attorney’s fee award were vacated and remanded for reconsideration. The court otherwise affirmed the superior court’s judgment. View "Johnson v. Albin Carlson & Co." on Justia Law

A man was injured while working on a man-made island in the Beaufort Sea, which served as an oil and gas drill site. In February, he drove a forklift down a ramp to unload cargo from a sled on the frozen sea. A colleague followed in a wheel loader, lost control, and collided with the sled and the forklift, crushing the man's leg. The man sued the companies owning and operating the island, alleging coverage under the Longshoreman and Harbor Workers’ Compensation Act (LHWCA) and maritime tort jurisdiction.The Superior Court of Alaska dismissed the man's LHWCA claims as unripe and ruled that the accident did not meet the two-prong test for maritime tort jurisdiction. The court found that the accident lacked the potential to disrupt maritime commerce and did not have a substantial relationship to traditional maritime activities. The court also concluded that the Alaska Worker’s Compensation Act (AWCA) barred the man from pursuing state law claims against the companies.The Supreme Court of Alaska reviewed the case. It held that the superior court properly dismissed the LHWCA-related claims, as eligibility for LHWCA benefits does not automatically establish maritime tort jurisdiction, and the LHWCA does not preempt the AWCA. However, the Supreme Court found that the superior court erred in its analysis of the maritime nexus prong. The accident had the potential to disrupt maritime commerce and bore a substantial relationship to traditional maritime activities, such as unloading cargo.The Supreme Court of Alaska reversed the superior court’s dismissal of the maritime tort claims and remanded the case for further proceedings to determine whether the accident met the locus prong of the maritime jurisdiction test. View "Beckwith v. ENI Petroleum US, LLC" on Justia Law