Justia Alaska Supreme Court Opinion Summaries

Seth Lookhart, a dentist, was convicted of numerous crimes related to a fraudulent scheme that endangered his patients' health and safety. The scheme involved unnecessary sedation of patients to fraudulently bill Alaska’s Medicaid program, overcharging it by more than $1.6 million. Lookhart also stole $412,500 from a business partner. His reckless sedation practices nearly resulted in the loss of two patients' lives. He was arrested in April 2017 and convicted on 46 charges in January 2020, leading to a sentence of 20 years in prison with eight years suspended.Following Lookhart's convictions, the Division of Corporations, Business and Professional Licensing sought to revoke his dental license. Lookhart agreed to the facts of the accusation but argued that revocation was not an appropriate sanction. The administrative law judge (ALJ) disagreed, stating that Lookhart's misconduct was more severe than any prior case and that revocation was the clear and obvious sanction. The Board of Dental Examiners adopted the ALJ's decision.Lookhart appealed to the superior court, arguing that the Board's decision was inconsistent with its prior decisions. The court disagreed, stating that the Board had wide discretion to determine appropriate sanctions and that no prior case was comparable to Lookhart's. The court affirmed the Board's decision. Lookhart then appealed to the Supreme Court of the State of Alaska.The Supreme Court affirmed the lower court's decision. It held that the Board of Dental Examiners did not abuse its discretion by revoking Lookhart's license. The court found that none of the Board's prior licensing cases involved misconduct of the scope and severity in this case, so there was no applicable precedent to limit the Board's exercise of its discretion. View "Lookhart v. State of Alaska, Board of Dental Examiners" on Justia Law

A teacher, who was involved in a car accident caused by a third party, sustained serious injuries. The teacher was covered under his employer’s self-insured healthcare plan, which stipulates that the employer has a right of reimbursement for medical expenses if a covered person receives a separate settlement. The employer paid for the teacher’s medical expenses and the teacher also received $500,000 in settlements from two separate insurers. The teacher requested that the employer waive its right to reimbursement twice, but the employer never agreed. Two years after the teacher notified the employer of his insurance settlements, the employer requested reimbursement and later sued him for breach of contract.The Superior Court of the State of Alaska granted summary judgment to the employer on the issue of whether the teacher breached the contract to reimburse the employer. The employer then moved for summary judgment on the amount of damages, providing an affidavit from its Plan Administrator and a claims ledger. The teacher opposed the motion, providing his own affidavit and a self-created spreadsheet in support of his argument that some of the medical costs paid by the employer were not associated with the accident. The court granted the employer’s motion for summary judgment on contract damages.The Supreme Court of the State of Alaska affirmed the lower court’s summary judgment order regarding breach of contract, but held that the teacher raised a genuine dispute of material fact regarding damages. Therefore, the Supreme Court reversed and remanded the lower court’s summary judgment order regarding contract damages. View "Fischer v. Kenai Peninsula Borough School District" on Justia Law

The case revolves around a dispute between a condominium association and the owner of two commercial units over parking and storage space. The commercial owner, Cooper Leasing, claimed ownership of certain parking spots and a storage area within the condominium property. The condominium association, Woronzof Condominium Association, disputed this claim.The Superior Court of the State of Alaska ruled that the condominium’s governing documents did not grant the commercial owner ownership of any parking spots. However, it ruled in favor of the commercial owner on the storage dispute, finding that the association had agreed decades earlier to swap the condominium’s general storage area with the area designated for commercial storage.Cooper Leasing appealed the ruling on parking, and the association cross-appealed the ruling on storage. The Supreme Court of the State of Alaska affirmed the ruling on parking, but vacated the ruling on storage. The court held that the terms of the declaration, in light of relevant extrinsic evidence, were ambiguous as to whether it was intended to give the commercial units the exclusive rights to use certain parking spots. The court also held that owners of condominiums have a property interest in both their own units and in the common areas of the condominium. Because a special test for when the doctrine of quasi-estoppel can be used to defeat record title to real property was not applied to the commercial owner’s quasi-estoppel claim to the storage space, the court vacated and remanded for further proceedings. View "Cooper Leasing, LLC v. The Woronzof Condominium Association" on Justia Law

The case involves the Alaska Trappers Association and the National Trappers Association (collectively, the Trappers) who challenged a city ordinance enacted by the City of Valdez. The ordinance regulated animal trapping within the city limits, barring trapping in certain areas for the purpose of protecting public safety and domesticated animals. The Trappers argued that the ordinance was invalid and unconstitutional, asserting that it was preempted by state law and violated the Alaska Constitution.The Superior Court of the State of Alaska, Third Judicial District, Valdez, granted summary judgment in favor of the City of Valdez. The court concluded that the legislature's delegation of authority to the Board of Game was limited and did not grant the Board exclusive control of trapping. The court also determined that the ordinance did not directly contradict state regulations.Upon appeal, the Supreme Court of the State of Alaska affirmed the lower court's decision. The Supreme Court held that the ordinance was not prohibited by the Alaska Constitution or the legislature’s delegation of authority over fish and game to the Board. The court concluded that the ordinance was not impliedly prohibited by state law, as it was enacted pursuant to Valdez's authority to regulate land use and public safety, and was not substantially irreconcilable with the State's authority to regulate the conservation, development, or utilization of game. View "Alaska Trappers Association, Inc. v. City of Valdez" on Justia Law

The City of Valdez in Alaska appealed two orders by the Regulatory Commission of Alaska (RCA) related to the transfer of the Trans-Alaska Pipeline System (TAPS) from BP Pipelines (Alaska) Inc. (BPPA) to Harvest Alaska, LLC. The first order (Order 6) approved confidential treatment of certain financial statements submitted by the oil company and its affiliates. The second order (Order 17) approved the transfer of a required certificate and the authority to operate the pipeline. The Superior Court dismissed Valdez’s appeals, concluding that Valdez lacked standing, failed to exhaust available administrative remedies, and the case was moot. The court also ordered Valdez to pay a portion of the attorney’s fees of the oil company and other companies involved in the proceedings.The Supreme Court of the State of Alaska reversed the dismissal of the appeal of Order 6, affirmed the dismissal of the appeal of Order 17, and vacated the award of attorney’s fees. The court found that Valdez had standing to appeal both orders, the appeals were not moot, and Valdez had exhausted administrative remedies with respect to Order 6 but not Order 17. The court remanded the case for further proceedings. View "City of Valdez v. Regulatory Commission of Alaska" on Justia Law

A pilot, who was injured in an airplane crash in 1985, sought medical benefits for a 2016 spinal surgery and subsequent treatment, as well as for diabetes treatment related to his spinal treatment. The Alaska Workers’ Compensation Board denied his claim, concluding that the 1985 injury was not a substantial factor in the pilot’s spinal problems. The Board also excluded the testimony of the pilot’s biomechanics expert due to non-compliance with Board regulations. The Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision, finding substantial evidence in the record to support the Board’s decision and that the Board had not abused its discretion in its procedural rulings.The Supreme Court of the State of Alaska affirmed the Commission’s decision. The court found that substantial evidence supported the Board's decision that the 1985 injury was not a substantial factor in the pilot's spinal problems. The court also found that the Board did not abuse its discretion by excluding the testimony of the pilot's biomechanics expert due to non-compliance with Board regulations. The court further held that the Board did not have an obligation to secure the testimony of a particular witness, and that the pilot's failure to secure a witness's testimony did not create an obligation for the Board to do so. View "Jespersen v. Tri-City Air and Alaska Insurance Guaranty Company" on Justia Law

The Supreme Court of Alaska affirmed a lower court's decision that the Copper River Native Association (CRNA), a non-profit corporation formed by federally recognized Alaska Native tribes, is an arm of its member tribes and thus entitled to tribal sovereign immunity. The case arose when a former employee sued CRNA over her termination. The superior court dismissed her complaint, concluding that CRNA was an arm of its member tribes and therefore entitled to sovereign immunity. The former employee appealed, arguing that CRNA was not entitled to tribal immunity. The Supreme Court of Alaska agreed with CRNA that the legal landscape defining the contours of tribal sovereign immunity has shifted significantly since its 2004 decision in Runyon ex rel. B.R. v. Association of Village Council Presidents. The court adopted a multi-factor inquiry to determine whether an entity is entitled to “arm-of-the-tribe” immunity. Applying this multi-factor inquiry, the court concluded that CRNA is an arm of its member tribes and affirmed the superior court's decision. View "Ito v. Copper River Native Association" on Justia Law

The case involves a man, Dominic N., who was involuntarily committed for mental health treatment. Dominic N. has a history of being charged with sexual abuse of a minor and has been deemed incompetent to stand trial multiple times. He has been diagnosed with numerous mental health and behavioral conditions, including major depressive disorder, selective mutism, and borderline intellectual functioning. In 2021, he was again charged with sexual abuse of a minor and found mentally incompetent to stand trial. While at the Alaska Psychiatric Institute (API) for competency restoration, he was diagnosed with additional disorders, including antisocial personality disorder.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, held a competency hearing and found Dominic mentally incompetent. The court ordered his commitment to API for further evaluation and restoration. The State petitioned for an order authorizing Dominic’s evaluation to determine whether he was mentally ill and likely to cause harm to others. The court granted the petition, and API staff filed a petition for 30-day civil commitment. After a hearing, the court found that Dominic was mentally ill and likely to cause harm to others, and ordered his commitment to API for 30 days.Dominic appealed to the Supreme Court of the State of Alaska, arguing that the State failed to prove that he was mentally ill as defined by statute and that his diagnoses were the type of intellectual and developmental disabilities excluded from the definition. The Supreme Court affirmed the superior court’s order, concluding that there was clear and convincing evidence that Dominic suffered from mental illness that is more than his excluded disabilities. The court found that Dominic’s impulse control disorder and pedophilic disorder were distinct from his intellectual and developmental disabilities, satisfying the statutory definition of mental illness. View "In re Hospitalization of Dominic N." on Justia Law

The case revolves around a dispute between the City of Valdez and the Prince William Sound Oil Spill Response Corporation, the State of Alaska, Department of Revenue, and the State Assessment Review Board. The City of Valdez appealed the State's determination that certain property was not taxable. After nearly two decades of administrative and court proceedings, Valdez won. However, due to the length of the litigation, Valdez has not been able to collect taxes on the property that should have been taxed.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, ruled that even though the State wrongly determined certain property was not taxable, the State cannot now assess taxes on this property if more than three years have passed since the taxpayer filed its tax return. According to this ruling, taxes may be assessed on this property only for the most recent tax years. Valdez appealed this decision.The Supreme Court of the State of Alaska affirmed the superior court’s decision. The court held that the statutory text is clear and does not suggest that the legislature intended something other than the plain meaning of the text. The court also disagreed with Valdez's argument that it is impossible for a municipality to challenge a taxability determination in less than three years. The court concluded that AS 43.05.260’s three-year limitations period applies to tax assessments under AS 43.56, even if Revenue’s initial decision not to tax certain property was wrong. View "City of Valdez v. Prince William Sound Oil Spill Response Corporation" on Justia Law

Brennan Grubb was convicted of sexually abusing a minor, which resulted in severe emotional trauma for the young boy. The boy's mother, a teacher, resigned from her job to care for her son. Grubb pleaded guilty to the charges and was ordered by the superior court to pay restitution, including compensation for the mother's future lost wages and benefits. Grubb appealed the restitution order, arguing that his criminal conduct was not the proximate cause of the mother's future lost wages and benefits. The court of appeals agreed with Grubb and vacated the restitution order.The Supreme Court of the State of Alaska reversed the decision of the court of appeals. The court held that the mother's resignation from her teaching position was a reasonably foreseeable consequence of Grubb's criminal conduct. The court remanded the case to the court of appeals for further proceedings consistent with its opinion. The court emphasized that the legislature has steadily expanded the rights of crime victims to obtain restitution and that the statutory right to restitution must factor into the proximate cause analysis. The court also noted that the statutory definition of "victim" necessarily affects the proximate cause analysis. The court concluded that it was error to hold as a matter of law that Grubb's conduct could not be the proximate cause of the mother's future lost wages and benefits. View "State v. Grubb" on Justia Law