Justia Alaska Supreme Court Opinion Summaries

Luciano G. appealed a court order involuntarily committing him for mental health treatment. He argued the court erred in making two findings: (1) that as a result of his mental illness he posed a risk of harm to others; and (2) that there was no less restrictive alternative to committing him to the Alaska Psychiatric Institute (API). He contended his conduct did not meet the statutory criteria of “likely to cause serious harm” and that there was insufficient evidence presented that there was no less restrictive alternative for his treatment. Because the Alaska Supreme Court found the superior court’s findings were supported by clear and convincing evidence, and the superior court properly determined that the man’s conduct met the statutory criteria, it affirmed the commitment order. View "In the Matter of the Necessity for the Hospitalization of Luciano G." on Justia Law

A juvenile from a small village could not afford to travel to the site of his juvenile delinquency proceeding. His attorney with the Public Defender Agency (the Agency) filed a motion asking the superior court to require the Division of Juvenile Justice (DJJ) to pay the travel expenses for both the juvenile and one of his parents. The superior court denied the motion and required the Agency to pay the expenses. The court of appeals upheld the superior court’s decision, reasoning that the Agency’s authorizing statute could plausibly be interpreted to cover client travel expenses and that this reading was supported by administrative guidance in the form of two Attorney General opinions and a regulation governing reimbursements by the Office of Public Advocacy (OPA). The Alaska Supreme Court granted the Agency’s petition for hearing, asking the Agency and DJJ to address two questions: (1) whether the Agency has a statutory obligation to pay its clients’ travel expenses; and (2) whether DJJ has a statutory obligation to pay those expenses. The Supreme Court concluded neither entity’s authorizing statutes required the payment and therefore reversed the court of appeals. The Court did not address the question of how these necessary expenses were to be funded; the Court surmised that was an issue for the executive and legislative branches. View "Alaska Public Defender Agency v. Superior Court" on Justia Law

This case arose from a boundary dispute between the Collinses and the Halls, who were adjoining property owners in a recreational subdivision on an island near Juneau, Alaska. The Collinses alleged that structures on the Halls’ property encroached onto the Collinses’ property and violated the subdivision’s restrictive covenants. They brought claims for quiet title and trespass based on boundaries recorded in a 2014 survey of their lot. This survey was prepared by the same surveyor who had initially platted the subdivision in the mid-1970s; the 1970s survey in turn referred to a survey monument established in 1927. The Halls responded that the Collinses’ surveyor had used the wrong point of beginning for his subdivision survey; that a surveyor they had hired in 2012 found the true point of beginning based on the 1927 survey; that the correct property boundary lay some distance from where the Collinses claimed; and that the supposedly encroaching structures were fully on the Halls’ land. The superior court found that the boundary advocated by the Halls was correct and issued a judgment quieting title based on their 2012 survey, though it acknowledged that its decision could cloud title for other property owners on the island. The court also found that the restrictive covenants at issue had been abandoned and concluded they could not be enforced against the Halls. The Alaska Supreme Court concluded the superior court’s findings as to the boundary location and restrictive covenants were not clearly erroneous, and therefore affirmed the court’s decision on those issues. But because the superior court’s findings and conclusions did not address one of the Collinses’ trespass claims, the matter was remanded for consideration of that issue. View "Collins v. Hall" on Justia Law

Adam and Kyoko Perry married in November 2005 and had two minor children. For the latter part of their marriage, Kyoko handled the couple’s finances. Kyoko continued her education while married, obtaining a bachelor’s degree and a master’s degree and incurring approximately $84,000 in debt. AKyoko testified that she obtained a master’s degree so she could defer her loan payments while Adam was temporarily unemployed. She stated that she feared they could not afford the loan payments while Adam was out of work. Adam decided to leave his job and was temporarily unemployed for a period of 34 days in early 2015, around the same time that Kyoko’s student loan payments began. Adam filed for divorce in March 2017. Kyoko objected when the divorce decree classified a portion of her student loan debt as non-marital. She also argued the court improperly calculated the parties’ income for child support purposes. Because the superior court applied the wrong legal standards to determine whether the student loan debt was marital and to calculate the parties’ incomes for child support purposes, the Alaska Supreme Court vacated the superior court’s final property distribution and child support orders and remanded for the court to conduct the proper legal analysis. View "Perry v. Perry" on Justia Law

Borrowers brought suit alleging that their lending bank had engaged in fraudulent real estate lending practices. The bank responded that statutes of limitations barred the borrowers’ fraud claims. Following an evidentiary hearing to establish relevant dates for the statutes of limitations inquiry, the superior court entered judgment and awarded attorney’s fees in the bank’s favor. The borrowers appealed, arguing that the superior court erred in its factual and legal determinations and otherwise violated their due process rights. Finding no reversible error, the Alaska Supreme Court affirmed the superior court’s rulings. View "Taffe v. First National Bank of Alaska" on Justia Law

In 2015, then-21-year-old G.L. was arrested after allegedly firing a loaded shotgun at buildings and people in his village. G.L. faced criminal charges related to the shooting, but the superior court ultimately ruled him mentally incompetent for criminal proceedings and in 2016 committed him to Alaska Psychiatric Institute (API) for competence restoration. G.L. was diagnosed with schizophrenia. He refused to consistently take medications and “was becoming increasingly psychotic and paranoid and dangerous” while at API for competence restoration. G.L. appealed a 180-day involuntary commitment order, arguing that the evidence presented at the commitment hearing was outdated and insufficient to support concluding that he continued posing a risk of harm to others. Because the superior court correctly applied the involuntary commitment statute in this case, appropriately considering the patient’s recent history of conduct and demonstrated unwillingness to comply with treatment, the Alaska Supreme Court affirmed the commitment order. View "In the Matter of the Necessity for the Hospitalization of G.L." on Justia Law

In a case of first impression for the Alaska Supreme Court, at issue was the use of electroconvulsive therapy (ECT) to a catatonic, non-consenting patient. In March 2017, police officers found Lucy G. in an Anchorage parking lot, wet and shivering. She was taken to a local hospital, where she initially exhibited “agitated, self-harming, and disoriented” behaviors requiring sedation for her and the staff’s safety. Lucy, who was calm but unresponsive by the end of the day, was diagnosed as catatonic. Hospital staff also noted her prior schizophrenia diagnosis and psychotropic medication prescriptions, as well as hospitalization the prior month. After a petition by hospital staff, the superior court authorized Lucy’s hospitalization for an involuntary commitment evaluation. She would ultimately be diagnosed with catatonia, involuntarily committed for 30 days, and given psychotropic medication and involuntary ECT. At the superior court hearing, the parties agreed that constitutional standards established in Myers v. Alaska Psychiatric Institute, 138 P.3d 238 (Alaska 2006) for ordering involuntary, non-emergency administration of psychotropic medication also applied to involuntary ECT. The patient argued there should have been heightened standards for ordering involuntary ECT and that, in any event, the superior court’s Myers analysis was legally deficient. The Alaska Supreme Court held that the superior court did not plainly err by applying the existing Myers constitutional standards to authorize involuntary ECT to the non-consenting patient. The Court also held the superior court made sufficient findings related to each relevant, contested mandatory Myers factor. Therefore, the Court surmised these findings supported the court’s involuntary ECT order. View "In the Matter of the Necessity of the Hospitalization of Lucy G." on Justia Law

The Board of Directors of the Girl Scouts of the United States of America increased the amount of annual membership dues. Farthest North Girl Scout Council, its executive director, and the chair of its board of directors challenged this increase, claiming that the corporation’s governing documents did not give the Board authority to increase membership dues. The superior court denied Farthest North’s motion for summary judgment, ruling in favor of the Girl Scouts of the United States of America that the Board had such authority. The Alaska Supreme Court disagreed, finding the corporate governing documents vested authority to establish membership dues solely in the National Council of the Girl Scouts of the United States of America. View "Farthest North Girl Scout Council v. Girl Scouts of the United States of America" on Justia Law

A minor died in a motorized watercraft accident on a lake managed in part by a municipality: the State owned the lake but shared management authority with the City. State law at the relevant time allowed motorized watercraft on the lake as long as they did not degrade or damage the lake or its surroundings. A State land use plan also covered the lake, but the plan did not appear to regulate watercraft use. Like the State’s land use plan, the City’s comprehensive land use plan required only that the lake be managed to preserve the area’s natural features. The City did not have a separate land use plan for the lake. The minor’s mother sued, claiming that the municipality negligently failed to take measures to ensure safe operation of motorized watercraft on the lake. The municipality sought summary judgment based on discretionary function immunity, which the superior court granted. Because the superior court correctly applied the doctrine of discretionary function immunity, the Alaska Supreme Court affirmed its decision. View "Haight,v. City & Borough of Juneau" on Justia Law

A hotel housekeeper injured her back while lifting a pile of linens. Her employer challenged her application for benefits based on an examining doctor’s opinion that she was medically stable and that the job injury was no longer the substantial cause of any disability or need for medical treatment. After a hearing, the Alaska Workers’ Compensation Board decided that the woman was medically stable as of the date of the doctor’s opinion and therefore not entitled to further disability payments or to benefits for permanent partial impairment. The Board also denied further medical care after the date of medical stability. The Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision, and the woman appealed. Because the Board’s selected date of medical stability was not supported by substantial evidence in the record, the Alaska Supreme Court vacated the Commission’s decision and remanded the case to the Commission with instructions to remand the case to the Board for further proceedings. View "Tobar v. Remington Holdings LP" on Justia Law