Justia Civil Rights Opinion Summaries

Articles Posted in Alaska Supreme Court

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An inmate representing himself sued the prison superintendent and chaplain for violating his religious rights by providing an inadequate halal diet, banning scented prayer oils, and not allowing him to have additional religious texts in his cell beyond the prison’s limit. He claimed these actions violated the Equal Protection Clause of both the Alaska Constitution and the federal Constitution, and the federal Religious Land Use and Institutionalized Persons Act (RLUIPA). The inmate also sought reimbursement for scented oils that the prison had destroyed. The superior court granted the prison officials’ motion for summary judgment and dismissed all of the inmate’s claims. The Alaska Supreme Court reversed summary judgment on the inmate’s RLUIPA claim regarding the halal diet because the inmate did not receive adequate guidance on how to file affidavits in opposition to the summary judgment motion. The Court also reversed summary judgment on the RLUIPA claim regarding scented oils because the prison officials failed to satisfy their burden of proving that banning such oils was the least restrictive means to address their substantial interest in maintaining prison security and health. The Court affirmed dismissal of the inmate’s claims regarding the religious book limit because the issue was not yet ripe. And the Court vacated the award of attorney’s fees and costs. View "Leahy v. Conant" on Justia Law

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Randell Jackson was charged with disorderly conduct, assault, and resisting arrest after a 2012 interaction with three police officers in Haines, Alaska. Amy Williams, an assistant district attorney, first prosecuted Jackson on these charges, but her efforts resulted in a mistrial. James Scott, the Juneau district attorney, oversaw the second round of proceedings against Jackson, which led to his conviction and sentencing. Jackson appealed his convictions in March 2016 to the superior court, which reversed his conviction for disorderly conduct but affirmed his assault and resisting arrest convictions. Jackson brought civil claims against the prosecutors who secured his convictions, alleging they committed various torts and violated his constitutional right to due process. The superior court dismissed his state and federal claims, concluding that the prosecutors enjoyed absolute immunity. The Alaska Supreme Court agreed the prosecutors were protected by absolute immunity from both the state and federal claims because they were acting in their official capacity as advocates for the State when they committed the acts that gave rise to the complaint. View "Jackson v. Borough of Haines, et al." on Justia Law

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The Alaska Workers’ Compensation Board denied a Bryce Warnke-Green's request that his employer pay for a van modified to accommodate his work-related disability. On appeal, the Alaska Workers’ Compensation Appeals Commission decided that a modifiable van was a compensable medical benefit. Warnke-Green moved for attorney’s fees. The Commission reduced the attorney’s hourly rate, deducted a few time entries, and awarded him less than half of what was requested. Warnke-Green asked the Commission to reconsider its award, but the Commission declined to do so because of its view that the Alaska Workers’ Compensation Act (the Act) allowed it to reconsider only the final decision on the merits of an appeal. The Alaska Supreme Court granted Warnke-Green's petition for review, and held that the Commission had the necessarily incidental authority to reconsider its non-final decisions. The Court also reversed the Commission’s award of attorney’s fees and remanded for an award that was fully compensable and reasonable. View "Warnke-Green v. Pro-West Contractors, LLC" on Justia Law

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Raymond Leahy was a prisoner at Goose Creek Correctional Center (Goose Creek). He was a practicing Muslim and identified himself as the Imam of the “Ummah of Incarcerated Alaskan Muslims.” He sued two prison superintendents, claiming that a mail policy instituted by the Alaska Department of Corrections (DOC) violated his religious rights because it prohibited him from writing letters to fellow Muslims in two other prisons. He asked for damages and a declaratory judgment that the mail policy violated the Alaska Constitution and the federal Religious Land Use and Institutionalized Persons Act (RLUIPA). The DOC rescinded the policy while the case was pending. The superior court granted summary judgment in favor of the superintendents, finding that the prisoner was not entitled to damages because the superintendents had not been personally involved in creating the policy and that his claims for non-monetary relief were mooted by the policy’s rescission. The prisoner appeals. The Alaska Supreme Court affirmed the superior court’s decision that the prisoner is not entitled to damages, though on different grounds: the superintendents were entitled to qualified immunity because the prisoner’s right to a religious exception from the mail policy was not “clearly established” under existing law. The Court also affirmed the superior court’s decision that the prisoner’s claim for declaratory relief was moot. View "Leahy v. Conant" on Justia Law

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A former employee of the Department of Health and Social Services (DHSS), Terri Reynolds-Rogers, brought a wrongful discharge suit against the State. At the time of her termination she had four union grievances pending against DHSS, and her union filed another based on the termination. The union settled all five grievances in exchange for a payment to the employee. She later sued DHSS for wrongful termination, alleging both breach of the covenant of good faith and fair dealing and several torts, including retaliatory discharge and failure to accommodate her disabilities. The superior court granted DHSS’s motion for summary judgment and entered final judgment against the employee. After review, the Alaska Supreme Court concluded the superior court was correct in deciding that the employee’s claims were resolved by the settlement of her grievances, were barred by the statute of limitations, or were legally insufficient in light of the undisputed facts. View "Reynolds-Rogers v. Alaska, Dept. of Health & Social Services" on Justia Law

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Kevin Patterson has been incarcerated since 2013, having been convicted after a bench trial of seven counts of possession of child pornography. In May 2015 Patterson filed a 121-page civil complaint in superior court in Juneau. The complaint named as defendants the governor and his predecessor, the Alaska Legislature, a state senator, the then-current and two former attorneys general, an assistant attorney general, an attorney with the Office of Public Advocacy, and the State of Alaska. The complaint alleged that these state officials and entities had “directly harmed . . . Patterson in numerous ways and [had] violated his Constitutional Rights over and over.” It sought damages for Patterson’s incarceration, violence and emotional distress he allegedly suffered while in prison, and the alleged denial of medical care. The Alaska Supreme Court affirmed dismissal of Patterson’s complaint, holding a civil suit for damages allegedly caused by a criminal conviction or sentence may not be maintained if judgment for the plaintiff would necessarily imply the invalidity of the conviction or sentence, unless the conviction or sentence has first been set aside in the course of the criminal proceedings. The Court also rejected Patterson’s claim that the superior court demonstrated an unfair bias against him. View "Patterson v. Walker" on Justia Law

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The Lum family sued two police officers and the North Slope Borough for trespass and invasion of privacy after an allegedly unlawful entry into the Lums’ home. The superior court dismissed both claims on summary judgment, reasoning that the officers were protected by qualified immunity under state law because the Lums had not produced sufficient evidence that the officers acted in bad faith. The Alaska Supreme Court reversed the superior court’s decision because there were genuine issues of material fact as to whether they acted in bad faith. View "Lum v. Koles" on Justia Law

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Alaska inmate David Simmons refused to provide a DNA sample for Alaska’s DNA identification registration system pursuant to a statutory requirement that persons convicted of certain crimes provide a DNA sample for the system. Refusal to submit a sample constituted a felony; for refusing the sample, he was charged with an infraction in a prison disciplinary hearing and found guilty. He appealed to the superior court, which affirmed. Simmons appealed to the Alaska Supreme Court, arguing primarily that the crimes for which he was found guilty and incarcerated occurred before the effective date of the DNA identification registration system, and the DNA sample requirement either was not retrospective or, if it was, violated the ex post facto clauses of the Alaska and U.S. Constitutions. A secondary issue raised by Simmons' appeal pertained to counsel in disciplinary proceedings. Because the inmate was charged with a disciplinary infraction constituting a felony, under Alaska case law he had the right to counsel in his disciplinary hearing. The Department of Corrections refused to provide him counsel for his hearing. The superior court ruled that although the denial of counsel violated the inmate’s constitutional rights, the violation did not prejudice his ability to have a fair hearing. Rejecting Simmons' contentions with respect to the sample-felony, and finding no other reversible error, the Supreme Court affirmed the superior court’s decisions. View "Simmons v. Alaska, Dept. of Corrections" on Justia Law

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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

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The City of Houston, Alaska fired its police captain shortly before disbanding its police department. The captain claimed he was terminated in bad faith in order to stop ongoing investigations into city leaders. He challenged: (1) the superior court’s refusal to allow his claim under the Alaska Whistleblower Act; (2) a jury instruction stating that termination for personality conflicts did not constitute bad faith; and (3) an award of attorney’s fees and costs. The Alaska Supreme Court concluded that the court’s refusal to allow his claim under the Whistleblower Act, its decision to give the personality conflict instruction, and its award of attorney’s fees and costs were not erroneous and therefore affirmed. View "McNally v. Thompson" on Justia Law