Justia Alaska Supreme Court Opinion Summaries

Federal law mandated a prison disciplinary decision include a written statement of the evidence relied on and the reasons for the decision. In this case, the superior court affirmed a decision finding a prisoner “guilty” without any further explanation. The court reasoned that the prisoner was not prejudiced because the disciplinary hearing was recorded, and the prisoner was able to adequately explain his version of the evidence in his appeal. The Alaska Supreme Court concluded the written disciplinary decision or the audio recording must ordinarily include a specific statement satisfying federal law: a mere finding of “guilty” is generally insufficient. The Court reversed the superior court’s decision affirming the decision of the Department of Corrections. View "Huber v. Alaska, Dept. of Corrections" on Justia Law

Alaska case law has treated the end of a domestic partnership as coextensive with both the end of a marriage-like relationship and the end of the partners’ cohabitation. But this appeal presented a novel factual circumstance of a couple who continued living together after their marriage-like relationship ended. The Alaska Supreme Court clarified several aspects of Alaska domestic partnership case law to decide this appeal, including when and how a domestic partnership terminates, when postpartnership payments must be reimbursed, and how the trial court should award attorney’s fees. Applying these clarified standards, the Court concluded most of the trial court’s property distribution was correct but that some minor aspects were in error. The Court therefore remanded for the trial court to revise its property division. View "Tomal v. Anderson" on Justia Law

An oil and gas lessee conducted drilling activity on the last day of the lease term; the lease provided that such activity would extend the term. Two days later, however, the Department of Natural Resources (DNR) sent the lessee a notice that his lease had expired. The lessee suspended drilling activities and asked DNR to reconsider its decision and reinstate the lease. DNR reinstated the lease several weeks later. The lessee contended that the reinstatement letter added new and unacceptable conditions to the lease, and pursued administrative appeals. Six months later DNR terminated the lease on grounds that the lessee had failed to diligently pursue drilling following the lease’s reinstatement. The superior court reversed DNR’s termination decision, finding DNR had materially breached the lease by reinstating it with new conditions. Both DNR and the lessee appealed to the Alaska Supreme Court. The Supreme Court concluded that although DNR breached the lease in its notice of expiration, it cured the breach through reinstatement. And DNR’s subsequent decision to terminate the lease was supported by substantial evidence that the lessee failed to diligently pursue drilling activities following reinstatement. Further, the Court concluded neither DNR nor the superior court erred in failing to address the lessee’s damages claim. The Supreme Court reversed the superior court’s decision reinstating the lease and affirmed DNR’s termination decision. View "Alaska, Dept. of Natural Resources v. Alaskan Crude Corporation" on Justia Law

Darcey and Matthew Geldermann, parents of a young son, divorced in 2011, agreeing that the mother would have primary physical custody during the school year. The father moved to California. When the child began experiencing behavioral problems, the parents agreed to switch custody for a few years, giving the father primary physical custody in California during the school year. The parties signed a custody modification agreement to this effect in December 2014, including both parents’ waivers of child support, but they did not file the agreement in court. The next year, following a dispute over the mother’s visitation, both parties sought a judicial resolution of custody. The father went to a California court seeking to make the 2014 change in custody permanent. The mother went to Alaska superior court seeking to enforce the original 2011 agreement that gave her primary physical custody. The Alaska court asserted jurisdiction; it ultimately modified physical custody in favor of the father but maintained the parents’ joint legal custody. The court also modified child support, ordering the mother to pay child support effective from the date the father first sought to modify custody in California. The mother appealed the physical custody and child support orders, challenging among other things the child support order’s effective date. The father cross-appealed, challenging the decision on joint legal custody. The Alaska Supreme Court affirmed the trial court’s custody and child support orders, concluding that they were well supported by the evidence, and that the court did not abuse its discretion in selecting the child support order’s effective date. View "Geldermann v. Geldermann" on Justia Law

The Commission for Human Rights is responsible for enforcing Alaska’s anti-discrimination laws. The Commission’s staff is authorized by regulation to use a variety of investigative methods. These include witness interviews, “inspection of documents and premises,” and “examination of written submissions of parties and witnesses.” The focus of this appeal was the Commission’s unwritten policy, followed for at least 27 years, barring third parties from investigative interviews with “certain limited exceptions.” As the Commission described its policy, third parties may be present if the interviewee is “the respondent named in the complaint, or is a member of the respondent’s ‘control group’ management, or has managerial responsibility.’ ” The Commission also allowed witnesses to be accompanied by their own attorneys and, if necessary, an interpreter or a guardian. The investigation at issue began when an employee filed two complaints against her employer, the State of Alaska Department of Health and Social Services (DHSS), in August 2014 and February 2015. The Commission opened an investigation headed by investigator Patricia Watts. Watts contacted Dori Anderson, the complainant’s supervisor, to schedule an interview. A question was raised over whether Greta Jones, a program manager for the complainant’s agency, was requested to attend Anderson’s interview. The Commission issued a subpoena to interview the complainant’s supervisor, who refused to be interviewed unless an employer representative was also present. On the Commission’s petition, the superior court issued an order to show cause why the supervisor should not be held in contempt. The supervisor moved to vacate the order and dismiss the contempt proceeding; the superior court granted the motion on the ground that the Commission lacked the legal authority to exclude third parties from its investigative interviews. The Commission appealed. The Alaska Supreme Court concluded the statutory requirement of a confidential investigation, with its specific limits on a respondent’s access to investigative materials, clearly authorized the Commission to exclude third parties from investigative interviews. The Supreme Court therefore reversed the superior court’s order dismissing the Commission’s petition and remanded for further proceedings. View "Alaska State Commission for Human Rights v. Anderson" on Justia Law

The Alaska Democratic Party amended its bylaws to allow registered independent voters to run as candidates in its primary elections without having to become Democratic Party members. But the Division of Elections refused to allow independent voter candidates on the Democratic Party primary election ballot, taking the position that Alaska election law, specifically the “party affiliation rule,” prevented anyone not registered as a Democrat from being a candidate in the Democratic Party’s primary elections. The Democratic Party sued for declaratory and injunctive relief preventing enforcement of the party affiliation rule, and the superior court ruled in its favor. The State appealed. Because the Alaska Constitution’s free association guarantee protects a political party’s choice to open its primary elections to independent voter candidates, and because in this specific context the State had no countervailing need to enforce the party affiliation rule, the Alaska Supreme Court affirmed the superior court’s decision. View "Alaska v. Alaska Democratic Party" on Justia Law

A self-represented couple sued their lawyer for legal malpractice. After lengthy and contentious discovery disputes, at the end of which the couple was sanctioned, the couple retained counsel to assist them in terminating the litigation. The parties agreed to dismiss the suit with prejudice, leaving open the couple’s former lawyer’s right to seek an award of attorney’s fees. At issue in this appeal was the superior court’s decisions regarding that lawyer’s motion for attorney’s fees. The superior court applied Alaska Civil Rule 82 for its award of partial reasonable attorney’s fees to the lawyer. But instead of employing Rule 82(b)(2)’s standard 20% calculation for an award without a money judgment, the court applied Rule 82(b)(3), which allowed courts to vary from the standard award. The court made findings and exercised its discretion to use 15% for calculating its fee award to the lawyer, and it left the discovery sanction against the couple in place. The Alaska Supreme Court concluded that the superior court’s findings were not clearly erroneous and that the court did not abuse its discretion or otherwise err when it applied Rule 82(b)(3); furthermore, the Court also concluded the superior court did not abuse its discretion in levying and leaving in place the discovery sanction. View "Boiko v. Kapolchok" on Justia Law

One night in February 2014 Carlile Transportation Systems, Inc. driver Bart Neal was driving a tractor-trailer southbound on the Dalton Highway. Neal could not steer properly at speeds above 35 miles per hour and decided to stop to put chains on his tires, partially blocking both traffic lanes, and, by his account, activated his flashers. Neal did not deploy reflective triangles. Eggor Enterprises, Inc. driver Joe Seurer was hauling a load of fuel northbound. By his account, Seurer saw lights in the distance but could not determine what they were. Seurer slowed his tractor-trailer from 50 to 35 miles per hour. About three-quarters of a mile from Neal, Seurer again saw lights and thought they might be from a pipeline maintenance truck stopped off the side of the road. He did not see reflective triangles or flashers. The road had an S-curve between Seurer and Neal. Until Seurer rounded the final curve, he did not realize Neal’s rig was blocking the road. Seurer applied his brakes about 300 feet from Neal, avoiding a serious collision but causing Seurer’s trailer to fall onto the side of the highway. The trailer’s fuel load spilled alongside the road. Eggor Enterprises’s insurer, HDI-Gerling American Insurance Company (HDI), paid over $3.5 million in cleanup costs to remediate the spill. HDI-Gerling, as subrogee of its trucking company client, sued Carlile for negligence. After a trial the jury determined that Carlile company’s driver was not negligent and returned a defense verdict. The insurance company appealed some of the superior court’s trial rulings. Seeing no reversible error, the Alaska Supreme Court affirmed the superior court’s entry of final judgment. View "HDI-Gerling America Insurance Company v. Carlile Transportation Systems, Inc." on Justia Law

A complaint filed with the Alaska Public Offices Commission (APOC) against John Eberhart was filed when he was a city council member, alleging Eberhart had improperly used government resources in his campaign for mayor of Fairbanks. After investigating the complaint and holding a hearing, APOC fined Eberhart $37.50 for improper use of government resources in violation of a state statute. Eberhart appealed to the superior court, which affirmed APOC’s decision. Eberhart petitioned the Alaska Supreme Court to find APOC misinterpreted and misapplied relevant statutes, violated the First Amendment, and violated its own procedural rules. The Supreme Court affirmed APOC’s decision, holding that Eberhart’s arguments lacked merit. View "Eberhart v. Alaska Public Offices Commission" on Justia Law

Allstate Insurance Company denied underinsured motorist (UIM) coverage to Nathan Ball for an accident involving his own vehicle after determining he was not an insured person under his then-fiancée’s parents’ Allstate automobile insurance policy. Ball contended that his fiancée was a “policyholder” for purposes of her parents’ policy, a necessary predicate to his argument for UIM coverage under the policy. But the policy declarations page did not list “policyholders,” it listed only “named insureds” and “drivers.” The superior court granted summary judgment on grounds that the policy language was not ambiguous because “policyholder” referred only to the parents, the “named insureds,” that the fiancée as only a listed driver, had no objectively reasonable expectation that she was a policyholder, and, therefore, that Allstate did not have a duty to provide Ball UIM coverage. The Alaska Supreme Court agreed “policyholder” encompassed only the named insureds, not listed drivers, and therefore affirmed the superior court’s decision. View "Ball v. Allstate Insurance Company" on Justia Law