Justia Alaska Supreme Court Opinion Summaries

Alex H., a prisoner, challenged the superior court’s denial of his request for transport to attend in person his parental rights termination trial, and, therefore, the ultimate termination of his parental rights. He argued that when denying his transport request the superior court: (1) abused its discretion by concluding in its statutory analysis that transport was not required; (2) abused its discretion or erred by failing to consider all required factors for the statutory analysis; and (3) separately violated his due process rights by denying him in-person attendance at the parental rights termination trial. Because the superior court considered all relevant factors the parties presented to it, because it was not obvious that considering additional factors would have changed the court’s statutory analysis, and because the prisoner’s due process rights were not violated, the Supreme Court affirmed the superior court’s transport decision and ultimate termination of the prisoner’s parental rights. View "Alex H. v. Dept. of Health & Social Services" on Justia Law

Central Recycling Services, Inc. recovered post-consumer materials for reuse, mainly from construction and demolition waste. The company requested rebates under a municipal ordinance providing reduced fees for disposing solid waste residue at the municipal landfill. The municipal department dispersing the rebates construed the ordinance as resulting in lower rebates than the company expected. The company sued the municipality, and the superior court ruled in the municipality’s favor. Central Recycling appealed. Although the ordinance language was imperfect, the Supreme Court concluded legislative intent more strongly supported the municipality’s interpretation. Therefore, the Court affirmed the superior court’s decision. View "Central Recycling Services, Inc. v. Municipality of Anchorage" on Justia Law

A self-employed real estate broker, James Studley, ran as a candidate for local elective office. The broker sought a blanket exemption from Alaska’s financial disclosure requirements to avoid reporting his clients’ identities and the income earned from them. The Alaska Public Offices Commission denied the broker’s request and assessed a $175 civil penalty for his failure to comply with the candidate reporting requirements. On appeal the superior court upheld the Commission’s ruling. The broker appealed, contending the disclosure requirements violated his duty to maintain client confidentiality, infringe his clients’ privacy rights under the Alaska Constitution, and impair several personal constitutional rights. After review, the Supreme Court affirmed the superior court’s decision upholding the Commission’s ruling. View "Studley v. Alaska Public Offices Comm'n" on Justia Law

A driver lost control of his truck and crashed into a cabin, causing property damage and personal injuries to the cabin owner. The cabin owner brought suit against both the driver and the driver’s insurance company, alleging in part that the insurance company subsequently took charge of and negligently handled the fuel spill cleanup on the cabin owner’s property. The superior court granted the insurer summary judgment, concluding as a matter of law that the insurer could not owe the cabin owner an actionable duty. The cabin owner appealed, arguing that Alaska case law did not preclude a duty in this context. The Supreme Court agreed with the cabin owner and therefore reversed the superior court’s grant of summary judgment. View "Burnett v. Government Employee Ins. Co." on Justia Law

A student was dismissed from a Ph.D. program at the University of Alaska Fairbanks after several years of poor performance and negative feedback. She claimed that her advisors discriminated and retaliated against her, that she was dismissed in violation of due process, and that the University breached duties owed to her under an implied contract. After review, the Alaska Supreme Court affirmed the superior court's decision to uphold the University's action because the student was dismissed based on her poor research performance and the dismissal was conducted under adequate procedures and within accepted academic norms. View "Horner-Neufeld v. University of Alaska Fairbanks" on Justia Law

A woman's premarital student loan was consolidated with other student loans incurred during marriage. Her husband argued at the couple's divorce trial that he should not be responsible for the consolidated loans because they contained the premarital debt and because his wife had wasted loan proceeds by gambling. The superior court, however, held the parties equally responsible for the loans, finding that it was impossible to extricate the premarital loan from the consolidated loans and that the amounts were all marital debt primarily used to support the family while the wife attended school. It further found that the husband had failed to prove a waste of marital assets. The husband argued on appeal to the Supreme Court that these findings were erroneous and that the superior court was biased against him. Concluding that the court's findings were supported by the evidence and that there was no merit to the bias allegation, the Supreme Court affirmed. View "Wagner v. Wagner" on Justia Law

Two co-conservators filed a motion to intervene in a lawsuit involving their ward in order to seek relief from a judgment based on a settlement agreement. The superior court denied the motion, and the co-conservators appealed. After review, the Supreme Court concluded that the co-conservators were entitled to intervene as a matter of right under Alaska Civil Rule 24 and that the denial of their motion to intervene was not harmless error. Accordingly, the Court reversed the superior court's order denying the motion to intervene and remanded for further proceedings. View "Hopper v. Estate of Goard" on Justia Law

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