Justia Alaska Supreme Court Opinion Summaries

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

In the case before the Supreme Court of the State of Alaska, the petitioner, Eric McDonald, an employee of a subcontractor, suffered injuries during the renovation of a high school. He sued Architects Alaska, Inc. and BBFM Engineers, Inc., alleging that they negligently failed to exercise reasonable care in the design, supervision, implementation, and specifications of the demolition of the renovation project. Before trial, the parties’ attorneys discussed the possibility of a settlement, and the defendants moved to enforce a “walk-away” settlement they claimed had been reached through email correspondence. McDonald, unrepresented at this point, did not file a substantive response to the defendants’ motion. The superior court granted the defendants’ motion and dismissed the case.About a year later, McDonald moved for relief from judgment under Alaska Rule of Civil Procedure 60(b), arguing that he had never given his attorney authority to settle the case. A different superior court judge granted the motion, finding that factual issues precluded summary judgment on whether a settlement agreement existed, that the earlier dismissal was erroneous as a law matter, and that extraordinary circumstances otherwise entitled McDonald to Rule 60(b) relief. The defendants petitioned for review, and the Supreme Court of the State of Alaska reversed the ruling on the ground that McDonald’s Rule 60(b) motion was not filed within a reasonable time. View "BBFM Engineers, Inc. v. McDonald" on Justia Law

In this case involving the State of Alaska, Department of Health & Social Services, Office of Children’s Services (OCS), the Supreme Court of the State of Alaska ruled on an appeal regarding the termination of parental rights of parents Allie P. and Jimmy E. The crux of the case revolved around the application of the Indian Child Welfare Act (ICWA), which provides specific protections for Indian children and their tribes in child custody proceedings.Allie P. and Jimmy E. had two children together and Allie had two older children from a previous relationship. All four children were removed from Allie’s custody due to her history of substance abuse. Jimmy E. claimed Alaska Native heritage and argued that his children should be considered Indian children under ICWA.The Supreme Court held that Jimmy did provide a sufficient reason to know that the two youngest children are Indian children and that OCS did not conduct a sufficient inquiry. Thus, the court vacated the termination of Jimmy’s and Allie’s parental rights as to the two youngest children and remanded for further proceedings.However, the court rejected Allie's additional challenges and affirmed the termination of her parental rights with respect to her two older children. The court found that Allie had not remedied the behavior causing her children to be in need of aid, OCS made reasonable efforts to reunite the family, and termination was in the children's best interests. View "Jimmy E. v. State of Alaska, Department of Health & Social Services, Office of Children's Services" on Justia Law

In this case, a man identified as Sergio F. was taken into emergency custody after his religious delusions led him to walk naked along a road during the winter. Following this incident, the Superior Court of the State of Alaska ordered his evaluation at a treatment facility, and subsequently involuntarily committed him for up to 30 days of treatment. A subsequent petition led to the superior court ordering a 90-day involuntary commitment to the treatment facility, as it found that the man was gravely disabled and needed additional treatment.On appeal, the Supreme Court of the State of Alaska vacated the superior court’s 90-day commitment order. It agreed with the man's argument that there was insufficient evidence to show he was gravely disabled and that the court failed to determine whether his commitment to the treatment facility was the least restrictive alternative for his treatment. The Supreme Court emphasized that less restrictive alternatives to hospitalization must be considered before ordering involuntary commitment and that it was the state’s burden to show that those alternatives do not exist or are not feasible. The Supreme Court found that this did not happen in this case, as neither the parties nor the court engaged in the specific inquiry required to address the petition’s allegations that less restrictive alternatives were considered and rejected by the treatment facility. Therefore, the Supreme Court vacated the 90-day commitment order. View "In the Matter of the Necessity for the Hospitalization of: Sergio F." on Justia Law

In a case involving the State of Alaska's Office of Children’s Services (OCS), an adult relative, Taryn M., appealed the denial of her request to have custody of an Indian child, Marcy P., who was in the custody of OCS. Marcy P. had a severe congenital disease and required a bone marrow transplant. The Supreme Court of the State of Alaska affirmed the decision of the lower court, finding that OCS had demonstrated by clear and convincing evidence that Taryn M. was an unsuitable caretaker for Marcy P. The court established that the burden of proof was on OCS to show that a preferred placement under the Indian Child Welfare Act (ICWA) was unsuitable. The evidence presented showed that Taryn M. was unwilling to abide by Marcy’s treatment plans, with instances including not following medical advice for treating fevers and not returning Marcy after a visit as planned. The court concluded that Taryn M.'s actions demonstrated clear and convincing evidence that she was an unsuitable caretaker. View "Taryn M. v. State of Alaska, Department of Family & Community Services" on Justia Law

In a dispute between the State of Alaska, Department of Health & Social Services and Jennifer D. White and John P. Shannon, D.C., the Supreme Court of the State of Alaska had to consider whether an adjudicative agency could refuse to consider a contested legal question because the legislature had given a different agency authority over the contested legal issue. In this particular case, the employer disputed its liability under the Alaska Workers’ Compensation Act for an injured employee’s chiropractic care, alleging that the care provided was not compensable because it was outside the scope of the chiropractor’s license. The Alaska Workers’ Compensation Board decided it did not have jurisdiction to determine the chiropractor’s scope of practice because the legislature had granted that authority to the Alaska Board of Chiropractic Examiners. The Supreme Court of the State of Alaska affirmed the Commission’s decision, agreeing that the workers’ compensation agencies lacked jurisdiction to determine the boundaries of chiropractic practice in the context of this case. The court also agreed with the Commission’s discovery decision, concluding that the discovery was not relevant to issues within the Board’s jurisdiction. The court further affirmed the Commission’s decision that the treatments were compensable. View "State of Alaska, Department of Health & Social Services v. White" on Justia Law

In this case, the Supreme Court of the State of Alaska upheld a lower court's decision that Williams Alaska Petroleum, Inc. and The Williams Companies, Inc. (collectively, "Williams") were strictly liable for the release of hazardous substances at a North Pole refinery they previously owned and operated. The substances, including sulfolane, a purifying solvent, had contaminated local groundwater. The court also upheld the ruling that Williams was responsible for paying damages to the State of Alaska and making contributions to the current owner, Flint Hills Resources, for its remediation costs.The court rejected Williams's claims that sulfolane was not a hazardous substance under state law. It also rejected the argument that the company's due process rights were violated because, it argued, it did not have fair notice that its conduct was prohibited. The court further denied Williams's argument that the imposition of retroactive liability for past releases constituted an unconstitutional taking of property.In addition, the court determined that Williams had retained liability for offsite sulfolane releases when it sold the refinery to Flint Hills. It also found that Flint Hills could seek statutory contribution from Williams for certain costs related to the contamination. However, the court remanded the grant of injunctive relief for more specificity as required by rule. Williams was ordered to pay damages for loss of access to groundwater due to sulfolane contamination, and for the costs of response, containment, removal, or remedial action incurred by the state. View "Williams Alaska Petroleum, Inc. v. State of Alaska" on Justia Law

In the case before the Supreme Court of the State of Alaska, the Attorney General for the State of Alaska, Treg R. Taylor, sued the Alaska Legislative Affairs Agency. The dispute arose from a disagreement between the executive and legislative branches over when an appropriations bill passed by the legislature would take effect, with potential implications for funding state government in the subsequent fiscal year. The Attorney General asked the court for a declaration that any expenditure of state funds without an effective appropriation was unlawful, unless the expenditure was necessary to meet constitutional obligations to maintain the health and safety of residents or federal obligations. The superior court dismissed the case, holding that the lawsuit was barred by a provision of the Alaska Constitution (article III, section 16) that prohibits the governor from suing the legislature. The Supreme Court of the State of Alaska affirmed that decision. The court held that, although the Attorney General brought the suit, it was in substance a suit brought by the Governor "in the name of the State" against the legislature. Therefore, it was barred by the Alaska Constitution. The Supreme Court also remanded the issue of attorney’s fees for further proceedings in the lower court. View "Treg R. Taylor, in his Official Capacity as Attorney General of the State of Alaska v. Alaska Legislative Affairs Agency" on Justia Law