Justia Alaska Supreme Court Opinion Summaries

A mother appealed an order reducing the amount of child support the father was required to pay. She argued that the superior court relied on incorrect income calculations from the Child Support Services Division (CSSD) and that it erred in finding a material change in circumstances sufficient to warrant a reduction in child support. She also argued that the court should have required the father to submit an income affidavit, and that its failure to do so improperly shifted to her the burden of proving the father’s income. After its review, the Supreme Court agreed that CSSD's income calculations were incorrect, that it was error for the court to adopt them, and that the father should have been required to submit an income affidavit. View "Shanigan v. Shanigan" on Justia Law

The sole question on appeal in this matter was whether the decedent's handwritten name at the beginning of the document was a "signature" as contemplated by AS 13.12.502(b). This was an issue of first impression, and the Alaska Supreme Court agreed with the superior court’s conclusion that a testator’s handwritten name in the exordium clause of a purported holographic will was sufficient to satisfy the signature requirement in AS 13.12.502(b) unless the instrument was otherwise incomplete. View "In Re Estate of Baker" on Justia Law

Oil producers (the Producers) challenged an administrative decision (the Decision) in which the Alaska Department of Revenue (DOR) decided to treat separate oil and gas fields operated by common working interest owners as a single entity when calculating the Producers’ oil production tax obligations. Relying on a statute that gave DOR the discretion to “aggregate two or more leases or properties (or portions of them), for purposes of determining [their effective tax rate], when economically interdependent oil or gas production operations are not confined to a single lease or property,” DOR concluded that operations on a number of smaller oil fields were economically interdependent with larger operations on the adjacent Prudhoe Bay oil field. The Producers argued that in interpreting the phrase “economically interdependent” in the Decision, DOR effectively promulgated a regulation without following the procedures established in the Alaska Administrative Procedure Act (APA) and, as a result, DOR’s Decision was invalid. After its review, the Supreme Court concluded that DOR’s Decision was not a regulation because it was a commonsense interpretation of the statute and, therefore, DOR was not required to comply with APA rulemaking requirements. The Court therefore affirmed the superior court’s decision upholding DOR’s decision. View "Chevron U.S.A., Inc. v. Dept. of Revenue" on Justia Law

In July 2012 Erin Long was driving toward Sitka when Robert Arnold turned his truck onto the road, cutting her off and forcing her into a ditch. Long was traveling approximately ten miles per hour when she drove off the road, and her car slowed to a stop as it contacted roadside bushes. Long’s car did not come into contact with Arnold’s truck or any other stationary roadside object. Long claimed she began to feel sore while on a flight to California two days after the accident. She subsequently sought medical treatment for her pain. Long later sued Arnold, alleging that his negligent driving caused her injury, medical expenses, economic loss, loss of enjoyment of life, and physical and emotional pain and suffering. The main issue in this negligence case was whether it was error for the trial court to give a causation instruction to the jury, "[t]he negligence was important enough in causing the harm that a reasonable person would hold the negligent person responsible." Finding no error in issuing that instruction, the Supreme Court affirmed. View "Long v. Arnold" on Justia Law

Two credit card holders defaulted on their accounts, and the issuing bank elected to litigate debt-collection actions. After courts entered default judgments against both card holders, the card holders filed new and separate suits alleging that the bank violated the Uniform Trade Practices and Consumer Protection Act (UTPA) during the earlier debt collection actions. The bank moved in each case to arbitrate the UTPA claims, and the superior court stayed the UTPA litigation and ordered arbitration. The issue presented for the Supreme Court's review was whether the bank waived its right to demand arbitration of the subsequent UTPA claims by litigating the debt-collection claims. Because the Court concluded that the two claims were not sufficiently closely related, it held that the bank did not waive its right to demand arbitration of the separate UTPA claims. But The Court also concluded that it was error for the superior court to interpret the arbitration agreement on the question of the availability of statewide injunctive relief: the interpretation of an arbitration agreement is in the first instance a matter for the arbitrator. View "Hudson v. Citibank (South Dakota) NA" on Justia Law

In September 2003, Bachner Company Inc. entered into a contract with the Alaska Department of Administration, to lease portions of the Denali Building in Fairbanks. After a ten-year lease term and a one-year renewal, Bachner alleged that the State was in default on its rent payments, and it filed suit in superior court to recover. The State moved to dismiss the complaint, arguing that the claim was governed by the Alaska State Procurement Code and that Bachner had failed to exhaust its remedies under the code before filing suit. The superior court agreed and granted the State’s motion to dismiss. Bachner appealed. After review, the Supreme Court concluded the procurement code covered a rent dispute over an ongoing lease, that the Bachner's claim fell under the procurement code, and Bachner had to exhaust its administrative remedies before filing suit in superior court. View "Bachner Company Incorporated v. State, Dept. of Administration" on Justia Law

School bus driver and appellant Jonathan Bockus injured his back moving a gate. He had two spinal surgeries, and his surgeon ultimately recommended a third. About the same time, the driver’s employer scheduled a medical examination, which delayed the planned surgery: the driver’s surgeon would not schedule the surgery while the employer’s medical evaluation was pending. So the driver filed a workers’ compensation claim for the third surgery, and the employer’s doctor ultimately agreed another surgery was appropriate. The Alaska Workers’ Compensation Board awarded the driver his attorney’s fees under AS 23.30.145(b), finding the employer had resisted these benefits, but the Alaska Workers’ Compensation Appeals Commission reversed the fee award. The Supreme Court concluded there was substantial evidence supporting the Board’s finding and therefore reinstated the award. View "Bockus v. First Student Services" on Justia Law

A woman was admitted to a hospital emergency room with pregnancy-related complications. The attending physician recommended that she be transported by medivac to a different facility. The woman and her husband informed the physician that they needed their insurer’s preauthorization for that course of action or they could be personally liable for the costs. The physician allegedly promised to call the insurer and, if it would not approve the medivac, have the hospital bear the costs itself. But the physician failed to contact the insurer until much later, and the insurer declined coverage. The couple sued the physician and the hospital, alleging that the physician breached her fiduciary duty by failing to obtain preauthorization as promised; that her promise created an enforceable contract, which was breached; and that if there was no contract the physician’s promise should be enforced through the doctrine of promissory estoppel. The superior court granted summary judgment to the physician and hospital. The couple appealed. After review, the Alaska Supreme Court held that the superior court did not err when it ruled in favor of the physician and hospital on the claims for breach of fiduciary duty and breach of contract, but that genuine issues of material fact precluded summary judgment on the claim for promissory estoppel. The Court reversed and remanded for further proceedings. View "Thomas v. Archer" on Justia Law

Providence Alaska Medical Center terminated Dr. Michael Brandner’s hospital privileges without notice and an opportunity to be heard after determining he had violated hospital policy by failing to report an Alaska State Medical Board order requiring him to undergo an evaluation of his fitness to practice medicine. Brandner unsuccessfully challenged this action through Providence’s internal post-termination hearing and appeal procedures. Brandner then sued in superior court, seeking reinstatement and damages for, in relevant part, alleged due process violations both in the procedures used and in the substantive standard applied in his termination. The superior court ruled that Brandner’s due process rights were not violated, that he was not entitled to reinstatement, and that under federal law Providence was entitled to immunity from his damages claims. After review, the Alaska Supreme Court affirmed the superior court’s decision concerning the substantive standard applied to terminate Brander; he therefore was not entitled to reinstatement or post-termination-hearing damages. But Brandner’s due process rights were violated by the procedures Providence employed because was not given required notice and a hearing prior to the termination of his hospital privileges; the Court therefore reversed the superior court’s decision on the pre-termination notice and hearing claim and its decision that Providence had damages immunity from this claim. View "Brandner v. Providence Health & Services - Washington" on Justia Law

A driver and his passengers sued another driver for injuries arising from an accident. After a trial, the jury returned an award of past pain and suffering damages for the driver, and past medical expenses and pain and suffering damages for one of the passengers. The driver and passengers appealed this award, arguing that it was impermissibly inconsistent and not supported by the weight of the evidence. Because the driver and passengers failed to challenge the jury verdicts before the trial court, all of their challenges were waived, and the Supreme Court affirmed the verdicts in full. View "Small v. Sayre" on Justia Law