Justia Alaska Supreme Court Opinion Summaries

The case involves the termination of parental rights of an incarcerated father, Anton K., to his two daughters, Allie and Melissa, who are Indian children under the Indian Child Welfare Act (ICWA). The Office of Children’s Services (OCS) removed the children from their parents' home due to allegations of abuse and neglect. Anton was later incarcerated on charges of physical and sexual assault against the children's mother, Keri K., and remained in custody throughout the proceedings.The Superior Court of Alaska, Third Judicial District, Palmer, initially found probable cause to believe the children were in need of aid and that OCS had made active efforts to avoid removing them. OCS developed case plans for both parents and facilitated some initial visitation. However, after Anton's incarceration, OCS's efforts to facilitate visitation and provide rehabilitative services were limited, partly due to COVID-19 restrictions and miscommunications with the Department of Corrections (DOC). OCS continued to work with Keri and the children's Tribe, eventually placing the children with maternal relatives after efforts to place them with paternal relatives failed.The Supreme Court of the State of Alaska reviewed the case and affirmed the Superior Court's order terminating Anton's parental rights. The court held that OCS had made active efforts to prevent the breakup of the family, considering the entirety of its efforts, including those directed at Keri and the children's extended family. The court acknowledged the significant gaps in OCS's efforts to facilitate visitation and provide services to Anton while incarcerated but concluded that the overall efforts, including those to reunify the children with Keri and place them with relatives, were sufficient under ICWA. View "Anton K. v. State" on Justia Law

Austin and Regena Joy owned property in Anchorage and leased it to Randy Hahn for his firewood business, Best Split Firewood, LLC (BSF). The lease included a purchase option for BSF to buy the property at a specified price and terms. Hahn signed the agreement, adding "Best Split Firewood" as the occupant, but Regena did not sign. Hahn later sought to exercise the purchase option, but the Joys refused, doubting the option's enforceability and Hahn's financial capability.Hahn filed a complaint in the Alaska Superior Court seeking a declaratory judgment to enforce the purchase option. The Joys denied the enforceability of the option and moved for summary judgment, arguing BSF could not enforce the option. Hahn opposed and filed a cross-motion for summary judgment, asserting the agreement was valid and enforceable. The Superior Court granted Hahn's motion, finding the agreement contained essential terms for a purchase option and that there was a meeting of the minds. The court also provided gap fillers for missing details and ordered specific performance, directing the Joys to sell the property to BSF.The Alaska Supreme Court reviewed the case and affirmed the Superior Court's decisions. The Supreme Court held that the agreement contained all essential terms for an enforceable purchase option and that BSF could exercise the option as Hahn's assignee, given Hahn's personal guarantee of BSF's obligations. The court also found that Hahn did not waive the purchase option by rejecting the Joys' offer, which contained errors and differed from the original agreement. Finally, the court rejected the Joys' unclean hands defense, finding no evidence of wrongdoing by Hahn related to the case. The Supreme Court affirmed the Superior Court's grant of summary judgment and order of specific performance. View "Joy v. Hahn" on Justia Law

A group of landowners (the Andersons) sued their neighbors (the Wilsons) over a property dispute involving access to remote parcels near a lake. The Andersons argued that a public easement existed over the Wilsons' property, providing access from a highway to their properties. They claimed this easement was established by patent, subdivision agreement, prescription, and under Revised Statute 2477 (RS 2477). The Wilsons contended that any access was permissive and private. The dispute arose after the Wilsons blocked access due to perceived excessive use by unauthorized individuals.The Superior Court of Alaska, Third Judicial District, held a 12-day bench trial. The court found in favor of the Wilsons, concluding that no public easement existed. It determined that the Andersons had only a private easement over the Wilsons' property. The court also awarded the Wilsons 75% of their attorney’s fees, finding them to be the prevailing party. The Andersons appealed both the easement determination and the attorney’s fee award.The Supreme Court of the State of Alaska reviewed the case. It affirmed the Superior Court's decision that no public easement existed, agreeing that the Andersons had not provided clear and convincing evidence of public use before the land was withdrawn from the public domain. The court also upheld the finding that no easement by implication, necessity, or estoppel existed. However, the Supreme Court vacated the attorney’s fee award and remanded it for further consideration. It found that the billing records were insufficiently detailed and included fees unrelated to the litigation. The court also noted that the hourly rates charged by the Wilsons' attorney were significantly higher than those customarily charged in the locality, requiring further examination of their reasonableness. View "Anderson v. Wilson" on Justia Law

A woman experiencing psychotic delusions was admitted to the Alaska Psychiatric Institute (API) for a mental health evaluation. Her treating psychiatrist identified three possible causes of her delusions, including psychosis secondary to lupus. Despite showing signs of improvement with antipsychotic medication, she was discharged against medical advice but was readmitted five days later. The superior court ordered a 30-day involuntary commitment, concluding there was clear and convincing evidence that she was gravely disabled due to mental illness.The superior court found that the woman was mentally ill and gravely disabled, based on the psychiatrist's testimony about her delusional beliefs and behaviors, such as believing she had psychic powers and was the subject of a non-consensual documentary. The psychiatrist also noted her refusal to eat or drink adequately, posing a medical concern. Despite the possibility of lupus, the psychiatrist recommended the same treatment for her psychosis and testified that a lupus diagnosis would not change his commitment recommendation.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court's commitment order. The court held that the statutory definition of "mental illness" does not exclude mental or emotional impairments resulting from physical conditions like lupus. The court also concluded that due process does not require ruling out physical conditions as the cause of mental illness. The psychiatrist's testimony provided clear and convincing evidence of the woman's mental illness, and the court found that involuntary commitment to API was the least restrictive alternative treatment available. View "In re Hospitalization of Kara K." on Justia Law

A child in the custody of the Office of Children’s Services (OCS) suffered severe abuse by his adoptive mother. Just before his 21st birthday, he filed a tort suit against OCS and his adoptive mother. OCS moved to dismiss the lawsuit as untimely. The child argued that the statute of limitations should be tolled for three reasons: it was tolled while he was in OCS custody until age 19, collateral estoppel should prevent OCS from arguing he was competent to file suit, and equitable tolling should apply. The superior court rejected these arguments and dismissed the suit as untimely.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, found that the child’s claims were barred by the two-year statute of limitations for tort claims. The court concluded that the statute of limitations was not tolled during the child’s extended foster care past age 18, as the age of majority in Alaska is 18. The court also found that the child was competent to file suit and that equitable tolling did not apply because the child had not demonstrated that extraordinary circumstances prevented him from filing on time.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court’s decision. The court held that the statute of limitations was not tolled during the child’s extended foster care because the age of majority is 18, and the extended foster care statute does not create an exception. The court also held that OCS was not estopped from arguing the child was competent because the issues in the conservatorship and partial guardianship proceedings were not identical to the issue of competency to file suit. Finally, the court held that equitable tolling did not apply because the child did not demonstrate that extraordinary circumstances made it impossible to file on time. The judgment of the superior court was affirmed. View "Blake J. v. State" on Justia Law

Samuel Amos fell from the roof of a shop building he was helping David Tidwell construct on property owned by Travis and Tabitha Plambeck. Tidwell had promised to pay Amos for his work. Amos filed a workers’ compensation claim against Tidwell and the Alaska Workers’ Compensation Benefits Guaranty Fund for his injuries. Tidwell requested the Alaska Workers’ Compensation Board dismiss Amos’s claim, alleging he had not hired Amos. The Board found that Amos had an employment contract with Tidwell but determined Tidwell was not an “employer” under the Alaska Workers’ Compensation Act, reasoning that the employment was based on friendship and thus fell within consumptive uses exempt from the Act’s coverage.The Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision, agreeing that Tidwell’s activities were consumptive rather than productive. The Commission also speculated that Amos’s work might fall under the statutory exemption for “harvest help and similar part-time or transient help,” although the Board had not made findings on this issue. Amos appealed, arguing that the Commission and the Board incorrectly construed the law and that there is no “buddy” exemption to the employer-employee relationship under the Act.The Supreme Court of the State of Alaska reviewed the case. The Court held that the Commission erred by creating an implicit exemption for “buddies” and by applying the productive/consumptive distinction to Tidwell’s employment of Amos. The Court clarified that the productive/consumptive distinction applies only to householders and not to individuals like Tidwell who hire others for work on third-party properties. The Court also found that the Commission improperly speculated about the applicability of the statutory exemption for part-time or transient help without proper findings. The case was reversed and remanded for further proceedings consistent with the opinion. View "Amos v. Tidwell" on Justia Law

The case involves a dispute over the control of a nonprofit corporation, which was dissolved by the State due to the executive director’s failure to pay taxes and fees and renew corporate registration. Despite the dissolution, the directors and members continued the corporation’s activities, unaware of the loss of corporate status. When the issue was discovered, some individuals filed paperwork to incorporate a new entity with the same name, offices, and bank account. A national affiliate proposed elections to resolve the leadership, but the new incorporators denied affiliation with the old corporation. Elections were held, and new directors were chosen, leading to litigation over who had authority to act on behalf of the new corporation.The Superior Court of Alaska, Third Judicial District, Anchorage, ruled that the new corporation was essentially the same entity as the old one, with the same members. The court concluded that the disputed election was valid and that the newly elected individuals had authority to act on behalf of the corporation. The court ousted the individuals who had filed the incorporation paperwork and awarded attorney’s fees to the prevailing parties but exempted individual litigants from liability for these fees.The Alaska Supreme Court largely affirmed the Superior Court’s rulings but vacated and remanded the dismissal of one third-party claim for a more detailed explanation. The court also vacated and remanded the Superior Court’s decision to excuse individual litigants from liability for attorney’s fees, finding the reason for this ruling invalid. The main holding was that the new corporation was the same entity as the old one, and the election of new directors was valid, giving them authority to act on behalf of the corporation. View "Aiken v. Alaska Addiction Professionals Association" on Justia Law

The case involves divorcing parents who had entered into a custody settlement agreement for their child, which included a provision for the child to move to New Jersey in 2022. The father later sought to modify this agreement, arguing that the child's emotional and behavioral health had deteriorated and that moving out of state would negatively impact the child's progress in therapy and school. The superior court found a substantial change in circumstances and awarded primary physical custody to the father, deciding that the child's best interests favored staying in Alaska.The superior court initially approved the custody settlement agreement but withheld judgment on the relocation provision. After further briefing, the court ruled that the relocation provision was enforceable but noted that the father could challenge it by demonstrating a substantial change in circumstances. The father filed a motion to modify custody, and after a trial, the superior court found that the child's emotional and behavioral issues had significantly worsened since the original agreement, constituting a substantial change in circumstances. The court concluded that the child's best interests required staying in Alaska with the father.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court's decision. The court found no clear error or abuse of discretion in the superior court's best interests analysis, which favored the father on several factors, including his capability and desire to meet the child's needs, the stability and continuity of the child's environment, and the willingness to facilitate a relationship with the other parent. The court also found that any error in admitting the parenting coordinator's reports was harmless, as the reports were largely cumulative of other evidence. The Supreme Court upheld the superior court's custody modification order, allowing the child to remain in Alaska with the father. View "J. M. v. S. C." on Justia Law

In July 2019, Tyler Blue, an inmate at Spring Creek Correctional Center, assaulted fellow inmate Patrick Torrence, causing abrasions, bruising, a mild concussion, and aggravation of a preexisting hip injury. Blue was criminally charged and pleaded guilty to assault in the fourth degree. In May 2022, Torrence filed a civil complaint against Blue, seeking damages for the injuries he sustained from the assault. Torrence's complaint referenced criminal statutes and sought restitution and compensation under various Alaska Statutes.The Superior Court of the State of Alaska, Third Judicial District, Seward, dismissed Torrence's complaint for failure to state a claim. The court concluded that the criminal statutes cited by Torrence did not support a private cause of action. Blue had argued that he could not be subjected to double jeopardy and that the court had already rendered judgment against him in the criminal case, including restitution. Torrence opposed the motion, asserting that the damages ordered in the criminal case were paid to the government, not to him, and that he had not been compensated for his injuries.The Supreme Court of the State of Alaska reviewed the case and concluded that Torrence's complaint, despite its reliance on criminal statutes, stated a claim for civil battery. The court held that the Superior Court erred in dismissing the complaint because Torrence had alleged facts consistent with a civil tort claim for battery. The court noted that the criminal conviction for assault did not preclude Torrence's civil suit for damages and that double jeopardy did not apply to civil claims. The Supreme Court reversed the Superior Court's dismissal and remanded the case for further proceedings, including providing procedural guidance to the self-represented litigants. View "Torrence v. Blue" on Justia Law

K.B., a patient at the Alaska Psychiatric Institute (API), has been under successive involuntary commitment orders since 2019 due to his diagnoses of schizoaffective disorder, antisocial personality disorder, and traumatic brain injury. His condition has led to violent outbursts and delusional behavior, resulting in his banishment from local shelters and hotels. In September 2022, Dr. Anthony Blanford, K.B.'s attending psychiatrist, filed another 180-day commitment petition. During the proceedings, K.B. expressed dissatisfaction with his appointed attorney, particularly over whether his trial would be by jury or bench.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, initially set the trial for late September. K.B.'s attorney informed the court that K.B. had requested a jury trial. However, on the first day of jury selection, K.B. indicated he preferred a bench trial. The court allowed defense counsel to consult with K.B., who confirmed his preference for a bench trial. The next day, K.B.'s attorney reported that K.B. had fired him for not listening and reiterated his preference for a bench trial. After further consultation, the attorney confirmed K.B.'s preference for a bench trial, and the court proceeded accordingly, ultimately granting the 180-day commitment petition.The Supreme Court of the State of Alaska reviewed the case. K.B. argued that the superior court erred by not conducting a representation hearing or inquiring further into his dissatisfaction with his attorney. The Supreme Court held that the superior court was not required to delve further into the attorney-client relationship. The court found that the circumstances, viewed objectively, did not indicate a breakdown in communication or decision-making capability between K.B. and his attorney. Therefore, the superior court's order granting the 180-day commitment was affirmed. View "In re Hospitalization of K.B." on Justia Law