Alaska Case Commentaries

Feasibility-and-Effectiveness Standard for “Less Restrictive Alternative” in Alaska Involuntary Medication and Commitment Orders

Date: Mar 13, 2026

Feasibility-and-Effectiveness Standard for “Less Restrictive Alternative” in Alaska Involuntary Medication and Commitment Orders Introduction This Alaska Supreme Court memorandum opinion...

ICWA “Active Efforts” May Center on Persistent Contact Attempts When a Parent Is Transient and Unengaged (Perfection Not Required)

Date: Mar 13, 2026

ICWA “Active Efforts” May Center on Persistent Contact Attempts When a Parent Is Transient and Unengaged (Perfection Not Required) Case: Kendall H. v. State of Alaska, Department of Family &...

Prison Discipline Due Process: “Some Evidence” Suffices When the Hearing Decision Incorporates a Detailed Incident Report

Date: Mar 13, 2026

Prison Discipline Due Process: “Some Evidence” Suffices When the Hearing Decision Incorporates a Detailed Incident Report Nonprecedential status. This is a memorandum opinion under Alaska Appellate...

Failure-to-Serve Dismissals Under Alaska Civil Rule 4 Must Be Without Prejudice Absent Clear Warning or Intent

Date: Mar 13, 2026

Failure-to-Serve Dismissals Under Alaska Civil Rule 4 Must Be Without Prejudice Absent Clear Warning or Intent Introduction Raymond Katchatag v. State of Alaska, Department of Corrections is a...

Excessive Corporal Punishment as “Assault or Reckless Endangerment” Supporting a Long-Term DVPO; Implicit Rule 52(a) Findings and Harmless Error in Bench DVPO Hearings

Date: Mar 13, 2026

Excessive Corporal Punishment as “Assault or Reckless Endangerment” Supporting a Long-Term DVPO; Implicit Rule 52(a) Findings and Harmless Error in Bench DVPO Hearings Introduction In Tyler C. v....

Certificate of Need: Alaska Department of Health May Waive the 40‑Bed Minimum Review Standard While Still Requiring CASU Methodology (No APA Rulemaking Required)

Date: Mar 1, 2026

Certificate of Need: Alaska Department of Health May Waive the 40‑Bed Minimum Review Standard While Still Requiring CASU Methodology (No APA Rulemaking Required) 1. Introduction Maple Springs...

Rule 82 Requires Segregated Proof of Reasonable and Necessary Fees Across Consolidated Claims

Date: Mar 1, 2026

Rule 82 Requires Segregated Proof of Reasonable and Necessary Fees Across Consolidated Claims Introduction Ralph Guditz v. Lakeside North Condominium Home Owners Association addresses a recurring...

Rule 82 Fee Awards Require Segregated Proof: Mixed Billing Across Claims Requires Vacatur and Remand

Date: Feb 28, 2026

Rule 82 Fee Awards Require Segregated Proof: Mixed Billing Across Claims Requires Vacatur and Remand 1. Introduction Ralph Guditz v. Lakeside North Condominium Home Owners Association (Alaska Supreme...

Failure to Make Domestic Violence Findings Requires Vacatur and Remand in Alaska Custody Determinations

Date: Feb 27, 2026

Failure to Make Domestic Violence Findings Requires Vacatur and Remand in Alaska Custody Determinations Introduction In Jordan F. v. Caitlin B. (Alaska Feb. 25, 2026) (Mem. Op. & J. No. 2135), the...

Federal Preemption Does Not Void a Dissolution Decree: Rule 60(b) Limits Collateral Attacks on Agreed Division of Military Disability/CRSC

Date: Feb 22, 2026

Federal Preemption Does Not Void a Dissolution Decree: Rule 60(b) Limits Collateral Attacks on Agreed Division of Military Disability/CRSC Introduction Jett M. Million v. Diane L. Hubert (Alaska Feb....

Unambiguous Indirect Identification Rule for Ballot-Measure Disclosure & Reporting (Alaska Policy Forum v. Alaska Public Offices Commission)

Date: Feb 15, 2026

Unambiguous Indirect Identification Rule for Ballot-Measure Disclosure & Reporting I. Introduction Alaska Policy Forum v. Alaska Public Offices Commission; Yes on 2 for Better Elections; and Protect...

Estate Removal Under Alaska’s Slayer Statute Requires Expert Proof Linking Alleged Delay in Care to Death; Enhanced Rule 82 Fees May Follow Unreasonable, Needlessly Complex Litigation

Date: Feb 6, 2026

Estate Removal Under Alaska’s Slayer Statute Requires Expert Proof Linking Alleged Delay in Care to Death; Enhanced Rule 82 Fees May Follow Unreasonable, Needlessly Complex Litigation Decision: In...

Alaska Probate Administration: Beneficiaries as “Interested Persons,” “Settlement” Includes Sale/Distribution, and AS 13.16.400 Notice Is Conflict-Triggered

Date: Feb 6, 2026

Alaska Probate Administration: Beneficiaries as “Interested Persons,” “Settlement” Includes Sale/Distribution, and AS 13.16.400 Notice Is Conflict-Triggered Nonprecedential posture: The court issued...

Reasonable Efforts in Non-ICWA CINA Cases: Mislabeling “Active Efforts” Does Not Alter the Legal Standard; Completing a Case Plan Alone Does Not Equal Remedy

Date: Jan 31, 2026

Reasonable Efforts in Non-ICWA CINA Cases: Mislabeling “Active Efforts” Does Not Alter the Legal Standard; Completing a Case Plan Alone Does Not Equal Remedy 1. Introduction This consolidated appeal...

Fee Arbitration Panels May Narrow Issues Under a “Reasonably Possible” Standard; Civil Rule 82 Fees Are Available in RUAA Post-Arbitration Proceedings

Date: Jan 25, 2026

Fee Arbitration Panels May Narrow Issues Under a “Reasonably Possible” Standard; Civil Rule 82 Fees Are Available in RUAA Post-Arbitration Proceedings Case: Leroy Oenga, Jr. v. Maria M. Givens,...

ICWA “Active Efforts” Must Be Evaluated Holistically and Tailored to Parental Noncooperation and Incarceration

Date: Jan 15, 2026

ICWA “Active Efforts” Must Be Evaluated Holistically and Tailored to Parental Noncooperation and Incarceration Introduction In Zeke N. (Father) v. State of Alaska, DFCS, OCS and Jordyn A. (Mother) v....

Waiver of Fee/Interest Challenges and Proof of “Reasonable and Necessary” Repair Costs in Insurer-Influenced Construction Disputes (Alaska)

Date: Jan 15, 2026

Waiver of Fee/Interest Challenges and Proof of “Reasonable and Necessary” Repair Costs in Insurer-Influenced Construction Disputes (Alaska) Case: FIRST EVANGELICAL COVENANT CHURCH OF ANCHORAGE ALASKA...

Enforcing DVIP Conditions in Custody Settlements: Supervised Visitation, Vexatious Contempt Motions, and Allocating the Risk of “24-Session” Mistakes

Date: Jan 15, 2026

Enforcing DVIP Conditions in Custody Settlements: Supervised Visitation, Vexatious Contempt Motions, and Allocating the Risk of “24-Session” Mistakes Important limitation: This decision is a...

Custody Modification: Increased Parental Stability and Child’s School Age as a “Substantial Change,” with Appellate Waiver for Inadequate Briefing

Date: Jan 15, 2026

Custody Modification: Increased Parental Stability and Child’s School Age as a “Substantial Change,” with Appellate Waiver for Inadequate Briefing Introduction In Rena M. Dalman v. Anthony M. Collado...

Holistic “Reasonable Efforts” Review in Alaska CINA Termination: Overall Adequacy Despite Discrete Lapses, Incarceration Constraints, and Pretrial Service Referrals

Date: Jan 15, 2026

Holistic “Reasonable Efforts” Review in Alaska CINA Termination: Overall Adequacy Despite Discrete Lapses, Incarceration Constraints, and Pretrial Service Referrals 1. Introduction Donny P. v. State...