Justia Alaska Supreme Court Opinion Summaries

This case revolves around the eligibility of Jennie Armstrong, the winning candidate of Alaska’s House District 16 2022 general election. The losing candidate, Liz Vazquez, along with four House District 16 voters, challenged Armstrong's eligibility, arguing that she had not been a resident of Alaska for at least three years before filing for office, as required by the Alaska Constitution. Armstrong maintained that she became a resident on May 20, 2019, while Vazquez argued that her residency did not begin until June 7, 2019. The superior court ruled in favor of Armstrong, declaring her eligible to serve in the legislature.On appeal, the Supreme Court of the State of Alaska affirmed the lower court’s decision. The Supreme Court agreed with the lower court's determination that Armstrong established her residency on May 20, 2019, but disagreed with the lower court's use of Title 15 to determine state residency. Instead, the Supreme Court held that Title 1, which states a person establishes residency in the state by being physically present with the intent to remain indefinitely and to make a home in the state, governs the state residency requirement for determining the eligibility of a legislative candidate. The Supreme Court found that Armstrong met the requirements of Title 1 and was therefore eligible to serve in the legislature. View "Vazquez v. Dahlstrom" on Justia Law

In this case, tenants Matthew Raines and Melissa Clayton complained to their landlord, Tuyen Dinh, about the habitability of their rented unit, particularly due to issues with their utilities and the presence of unauthorized tenants in the building. The tenants withheld rent and requested reimbursement for additional utilities costs. When Dinh refused and subsequently evicted the tenants for nonpayment of rent, a dispute ensued. The Superior Court of the State of Alaska held a damages trial, finding largely in favor of the tenants.The Supreme Court of the State of Alaska affirmed the lower court's findings that Dinh failed to maintain the premises in a habitable condition and willfully diminished the tenants' essential services under the Uniform Residential Landlord and Tenant Act (URLTA). However, the Supreme Court reversed the lower court's conclusion that the tenants could recover for the landlord's failure to deliver possession of the property. The Supreme Court also affirmed some aspects of the lower court's award of damages, but reversed those awards that were not supported by the record.The court found that Dinh's violation of housing codes and his conditional use permit diminished the value of the tenants' leasehold by the $8,800 owed in past rent. The court also found that Dinh was responsible for additional costs incurred by the tenants due to the unauthorized use of their utilities by unauthorized tenants in the building. However, the court ruled that the tenants could not recover for Dinh's failure to deliver possession of the property, despite finding that Dinh did not deliver habitable premises at the commencement of the lease. View "Dinh v. Raines" on Justia Law

In the case before the Supreme Court of the State of Alaska, MJ Corporation, the owner of an automated teller machine (ATM), sued Societe Financial, LLC, an ATM processor, and its owner, James Dainis, for breach of contract, conversion, and for piercing the corporate veil. MJ Corp. alleged that it had not been receiving its full share of transaction fees and reimbursement for vault cash dispensed by the ATM as per their agreement.The court reversed summary judgment on the breach of contract claim and piercing the corporate veil, as the processor presented genuine issues of material fact pertaining to those claims. The court held that while MJ Corp. presented admissible evidence of an implied contract and breach of the same, Dainis's affidavit raised a genuine dispute of material fact regarding the damages, thus barring summary judgment on the breach of contract claim.The court affirmed the superior court’s decision to grant summary judgment on the conversion claim. It found that MJ Corp. satisfied its prima facie burden for summary judgment, and Societe's evidence was too conclusory to present a genuine dispute of material fact regarding conversion.Regarding the claim to pierce the corporate veil, the court found that there was insufficient evidence on summary judgment to hold Dainis personally liable or to pierce the corporate veils of Societe's subsidiary company and another company owned by Dainis. The case was remanded for further proceedings in line with the court's opinion. View "Societe Financial, LLC v. MJ Corporation" on Justia Law

In this case, Lee Baker and Kenneth Duffus were partners in a real estate development company, Harvest Properties, LLC. Baker was accused of defrauding the company, leading to a lawsuit from the company's members for defaulting on a loan. Duffus cross-claimed against Baker, alleging Baker had violated the Unfair Trade Practices and Consumer Protection Act (UTPA). Baker argued that the UTPA did not apply since his conduct was part of a real estate transaction and was within the company's internal operations. The Supreme Court of the State of Alaska rejected Baker's arguments and affirmed the superior court's ruling. The court held that Baker's fraudulent actions were not part of a real estate transaction because they did not involve the actual transfer of an interest in real property. Instead, they interfered with the company's ability to realize larger, future real estate transactions. The court also held that the UTPA applies even when a party has a fiduciary relationship with a business entity if the parties also engage in arms-length commercial transactions. Baker's provision of services through his separate corporation was considered such an arms-length transaction. View "Baker v. Duffus" on Justia Law

In this case, the Supreme Court of Alaska ruled on the legal process applying to the Office of Children's Services (OCS) when it seeks to admit a child in its custody to a hospital for psychiatric care. The case centered on a minor named Mira J., a member of the Native Village of Kwinhagak (the Tribe), who was placed in OCS custody and hospitalized for 46 days for psychiatric treatment without a hearing to determine if the hospitalization was justified.The Tribe argued that her hospitalization should have been governed by the civil commitment statutes or, alternatively, that the constitution did not permit OCS to hospitalize a child for such a long time without a court hearing to determine whether the hospitalization was justified. The court rejected the Tribe's statutory argument but agreed that Mira's due process rights under the Alaska Constitution were violated.The court held that while OCS was not required to follow the civil commitment statutes when admitting Mira to either hospital, due process required OCS to promptly notify parties to the child in need of aid (CINA) case when admitting a child to the hospital for psychiatric care. Further, due process required the court to hold a hearing as soon as reasonably possible to determine whether the hospitalization was justified. The court held that the 46-day wait between Mira's first admission to the hospital and the hearing was too long to satisfy due process, and thus reversed the lower court's order authorizing Mira's continued hospitalization. View "Native Village of Kwinhagak v. State of Alaska" on Justia Law

In the case of Brett Lane v. the State of Alaska, Department of Family & Community Services, Office of Children’s Services, the Supreme Court of the State of Alaska affirmed the lower court's decision denying the Office of Children's Services's (OCS) post-trial motion for a new trial on liability. The court concluded that the weight of the evidence supported the jury's verdict on Lane's theories of retaliation. However, the court found an error in the jury instruction relating to noneconomic damages caused by a dangerous client, Wilson. As a result, the court vacated the damages judgment and remanded for a new trial solely on noneconomic damages. The court also remanded the matter back to the lower court for an evidentiary hearing on OCS's claim that the jury award duplicated workers’ compensation benefits that Lane received. The court held that OCS should be given the opportunity to prove that the jury award created an impermissible duplication of damages. View "State of Alaska v. Lane" on Justia Law

The Supreme Court of the State of Alaska affirmed the decision of the Superior Court to grant summary judgement in favor of an attorney, John Wallace, in a case brought against him by the estate of a deceased entrepreneur. The estate, represented by Courtney Guerra, blamed Wallace for the financial mismanagement of the estate by its previous personal representative, Robert Nesbitt, who Wallace had represented. The estate alleged that Wallace was liable for damages due to his negligent performance of duties as Nesbitt's attorney. However, the Supreme Court agreed with the lower court that Wallace had no duty of care to the estate's beneficiaries, as they were not his clients. Furthermore, the estate's claims of malpractice against Wallace were waived due to insufficient briefing in their appeal. The court concluded that Wallace didn't know or have reason to know that Nesbitt was mismanaging the estate's funds, and therefore, he had no legal duty to prevent or rectify Nesbitt's actions. View "Guerra v. Nesbitt" on Justia Law

In this case, a woman was severely injured while moving an inoperable airplane owned by her husband. She sought recovery from her husband's homeowner's insurance policy. The insurance policy, however, excluded injuries "arising out of" the ownership, maintenance, use, loading or unloading of an aircraft. The woman argued that the policy should cover her injury because, in her view, the aircraft had become mere "parts" after her husband removed the wings, elevators, and tail rudder. The lower court disagreed and concluded that her injuries were not covered by the policy. The woman appealed this decision.The Supreme Court of the State of Alaska agreed with the lower court’s interpretation of the homeowner's insurance policy exclusion. The court maintained that regardless of whether the airplane was considered an aircraft or a collection of airplane “parts” when it injured the woman, the injury arose out of the husband’s ownership of the airplane. This interpretation was supported by the clear language of the policy which excluded coverage for bodily injury arising out of ownership or maintenance of an aircraft. As a result, the court affirmed the lower court’s decision. View "Thompson v. United Services Automobile Association" on Justia Law

In the State of Alaska, a woman, Lacie Chance, left her boyfriend, Jason Armstrong, in California and relocated to Alaska with their daughter. She filed for a domestic violence protective order (DVPO) against Armstrong in Alaska, alleging seven years of physical and mental abuse. The superior court issued temporary 20-day protective orders and a long-term protective order against Armstrong, who had never been to Alaska. Armstrong appealed, arguing that the court lacked personal or subject matter jurisdiction. While the Supreme Court of the State of Alaska agreed with the lower court that it had subject matter jurisdiction to hear the case, it concluded that the superior court lacked the personal jurisdiction necessary to impose affirmative and long-term obligations on Armstrong, who had no contacts with Alaska. The court emphasized that due process requires either general or specific jurisdiction over a defendant. In this case, Armstrong had no contacts with Alaska, and therefore, the court did not have personal jurisdiction over him. The court concluded that the long-term DVPO could not stand because it imposed significant and potentially long-lasting restrictions and obligations on Armstrong. The DVPO was vacated. View "Armstrong v. Chance" on Justia Law

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