Justia Civil Rights Opinion Summaries

In this case, a man identified as Sergio F. was taken into emergency custody after his religious delusions led him to walk naked along a road during the winter. Following this incident, the Superior Court of the State of Alaska ordered his evaluation at a treatment facility, and subsequently involuntarily committed him for up to 30 days of treatment. A subsequent petition led to the superior court ordering a 90-day involuntary commitment to the treatment facility, as it found that the man was gravely disabled and needed additional treatment.On appeal, the Supreme Court of the State of Alaska vacated the superior court’s 90-day commitment order. It agreed with the man's argument that there was insufficient evidence to show he was gravely disabled and that the court failed to determine whether his commitment to the treatment facility was the least restrictive alternative for his treatment. The Supreme Court emphasized that less restrictive alternatives to hospitalization must be considered before ordering involuntary commitment and that it was the state’s burden to show that those alternatives do not exist or are not feasible. The Supreme Court found that this did not happen in this case, as neither the parties nor the court engaged in the specific inquiry required to address the petition’s allegations that less restrictive alternatives were considered and rejected by the treatment facility. Therefore, the Supreme Court vacated the 90-day commitment order. View "In the Matter of the Necessity for the Hospitalization of: Sergio F." on Justia Law

In the State of Alaska, a man diagnosed with bipolar disorder stopped taking his medication, experienced a manic episode, and was hospitalized as a result. The hospital staff petitioned for him to be involuntarily committed for 30 days, which the superior court granted. The man appealed, arguing against the court's decision that he was likely to cause harm to others, was gravely disabled, and that there was no less restrictive alternative to involuntary commitment. The Supreme Court of the State of Alaska held that the man's rights were violated because there was a feasible, less restrictive alternative to the involuntary commitment. The court also ruled that even if the suggested outpatient treatment proposal was not feasible, the State had failed to meet its burden of proving that no less restrictive alternative existed, as it did not consider any other treatment options beyond the man's proposal. The commitment order was vacated on these grounds. View "In the Matter of the Necessity of the Hospitalization of Declan P." on Justia Law

In this case from the Supreme Court of the State of Alaska, the court examined a claim brought by an inmate, Jeffrey Hout. Hout, who was convicted in 2010 of kidnapping and murder, accused Governor Michael Dunleavy of failing to provide him with proof of various bonds, oaths, and licenses, and alleged that certain people involved in his criminal trial had practiced law without valid licenses. He also filed a Uniform Commercial Code (UCC) Financing Statement seeking to secure a purported debt of $250 million in gold dollars owed to him by Governor Dunleavy and the State of Alaska. The superior court dismissed the lawsuit because it failed to state a claim upon which relief could be granted, prompting Hout to appeal.The Supreme Court of the State of Alaska affirmed the superior court’s decision. The court highlighted that Hout's claims were consistent with the expressed belief system of a group known as “sovereign citizens” and stated that courts across the country have universally rejected these types of claims. The court noted that their jurisdiction to decide the case was derived from Alaska citizens who have provided “consent of the governed” by ratifying the Alaska Constitution. The court rejected Hout's argument that Alaska’s laws do not apply to him unless he provides personal consent to be governed by those laws.On the merits, the court found Hout's fraud claim to be without merit. The primary allegation underpinning Hout’s fraud claim was that Governor Dunleavy was legally obligated to provide him with proof of oaths, licenses, and bonds. The court held that there was no legal basis for this claim. The court also dismissed Hout’s civil rights claim seeking release from prison on the ground that certain officials who participated in his criminal trial were practicing law without valid licenses. The court explained that the proper vehicle for Hout’s claim seeking release from prison would be an application for post-conviction relief. Since Hout had already applied once for post-conviction relief, any subsequent application would be dismissed. View "Jeffrey Hout v. State of Alaska, Office of the Governor" on Justia Law

In 2020 Alaska voters approved, by a slim margin, a ballot initiative that made sweeping changes to Alaska’s system of elections. The changes included replacing the system of political party primary elections with a nonpartisan primary election and adopting ranked-choice voting for the general election. A coalition of politically active voters and a political party filed suit, arguing that these changes violated the Alaska Constitution. The superior court ruled otherwise. The Alaska Supreme Court considered the appeal on an expedited basis and affirmed the superior court’s judgment in a brief order. The Court concluded the challengers did not carry their burden to show that the Alaska Constitution prohibited the election system Alaska voters have chosen. The Court published its opinion to explain its reasoning. View "Kohlhaas, et al. v.Alaska, Division of Elections, et al." on Justia Law

A patient sued a hospital after learning that a hospital employee intentionally disclosed the patient’s health information in violation of the Health Insurance Portability and Accountability Act (HIPAA). The patient alleged the disclosure breached the hospital’s contractual obligations to him. The superior court instructed the jury to return a verdict for the hospital if the jury found that the employee was not acting in the course and scope of employment when she disclosed the patient’s information. The jury so found, leading to judgment in the hospital’s favor. The Alaska Supreme Court found the jury instruction erroneously applied the rule of vicarious liability to excuse liability for breach of contract. "A party that breaches its contractual obligations is liable for breach regardless of whether the breach is caused by an employee acting outside the scope of employment, unless the terms of the contract excuse liability for that reason." The Court therefore reversed judgment and remanded for further proceedings, in particular to determine whether a contract existed between the patient and hospital and, if so, the contract’s terms governing patient health information. View "Guy v. Providence Health & Services Washington" on Justia Law

Several months after returning from maternity leave, an association’s employee accepted a new special projects position with reduced hours that allowed her to work from home. Later that year she was terminated; the association explained that there were no more special projects for her to work on and the position was no longer necessary. The employee filed suit, alleging that the association had unlawfully discriminated against her based on pregnancy and parenthood. Considering all the evidence before it, the trial court concluded that there were no genuine issues of material fact relevant to the employee’s discrimination claim, and that the association was entitled to summary judgment. The employee appealed, contending the superior court should not have considered the evidence submitted after the filing of the deficient motion and that, even if all evidence was considered, the association was not entitled to summary judgment. The Alaska Supreme Court concluded the superior court acted within its discretion by accepting the authenticating affidavit with the association’s reply, and that it properly considered all the evidence before it in granting summary judgment. View "Werba v. Association of Village Council Presidents" on Justia Law

Kaleb Basey, who was convicted of federal crimes, filed a federal civil rights lawsuit in January 2016 against several Alaska state troopers based on their actions during his investigation and arrest. In September, Basey submitted two public records requests to the Alaska State Troopers seeking various documents relating to the investigation of his case, including two troopers' disciplinary records. Basey's requests were promptly denied on the ground that the information pertained to pending litigation. Asking for reconsideration, Basey's request was again denied, again citing the pending litigation. Acting pro se, Basey appealed, and his appeal reached the Alaska Supreme Court. In 2017, the Supreme Court reversed a superior court's dismissal order, holding that neither disclosure exception the State used as grounds for resisting Basey's request had applied. Basey moved to compel production of the requested records in January 2018. The State responded by agreeing to produce certain records, denying the existence of others, and asserting that the requested disciplinary records were private personnel records exempt from disclosure. In a seonc trip to the Alaska Supreme Court, the issue before the Court was whether state employee disciplinary records were confidential “personnel records” under the State Personnel Act and therefore not subject to disclosure under the Alaska Public Records Act. To this, the Court concluded that, with one express statutory exception not relevant to this case, the answer was “yes.” View "Basey v. Alaska Dept. of Pub.Safety" on Justia Law

Psychiatrists employed by the Alaska Department of Corrections (DOC) diagnosed inmate Adam Israel with paranoid schizophrenia. The inmate disputed his diagnosis, contending that his claimed rare genetic ability to see the electro-magnetic radiation of poltergeists was misunderstood as a delusion. The inmate brought a medical malpractice action against the psychiatrists and DOC seeking rescission of his diagnosis and damages. DOC filed a motion for summary judgment supported by an affidavit from DOC’s chief medical officer. The affidavit confirmed the inmate’s diagnosis and asserted that the inmate received treatment consistent with his diagnosis. After notifying the inmate that he needed expert testimony to oppose the motion for summary judgment, the superior court granted DOC’s summary judgment motion because the inmate failed to provide expert testimony to rebut DOC’s evidence. Israel appealed, arguing that DOC’s medical director was not qualified to testify about the standard of care under AS 09.20.185. The Alaska Supreme Court determined Israel failed to create a genuine issue of material fact about the correctness of his diagnosis. Therefore, the Court affirmed the superior court’s grant of summary judgment. The Supreme Court also rejected Israel's other arguments raised on appeal. View "Israel v. Alaska, Department of Corrections" on Justia Law

This case involved prisoner Richard DeRemer's pro se appeal of the superior court’s dismissal of his civil complaint against three Alaska Department of Corrections (DOC) employees. DeRemer alleged numerous violations of his constitutional rights, and he requested declaratory relief and damages. The defendants filed a motion to dismiss the complaint addressing some, but not all, of DeRemer's claims. Specifically, the defendants did not address his First Amendment retaliation claim or request for declaratory relief. The court relied on this motion and dismissed the prisoner’s claims “for the reasons set forth in defendants’ motion,” failing to provide any independent analysis of the prisoner’s claims. Because the court, by adopting the defendants’ reasoning, failed to address all of the prisoner’s claims, the Alaska Supreme Court reversed the court’s order with respect to the First Amendment retaliation claim and remanded for further proceedings. The Supreme Court affirmed the court’s dismissal of the prisoner’s other claims. View "DeRemer, III v. Turnbull" on Justia Law

Luciano G. appealed a court order involuntarily committing him for mental health treatment. He argued the court erred in making two findings: (1) that as a result of his mental illness he posed a risk of harm to others; and (2) that there was no less restrictive alternative to committing him to the Alaska Psychiatric Institute (API). He contended his conduct did not meet the statutory criteria of “likely to cause serious harm” and that there was insufficient evidence presented that there was no less restrictive alternative for his treatment. Because the Alaska Supreme Court found the superior court’s findings were supported by clear and convincing evidence, and the superior court properly determined that the man’s conduct met the statutory criteria, it affirmed the commitment order. View "In the Matter of the Necessity for the Hospitalization of Luciano G." on Justia Law