Bottcher v. State, 300 P.3d 528

In May 2005 Bottcher, intoxicated, drove off the road and struck Saul Stutz, fatally injuring him; his younger brother was narrowly missed.
Bottcher fled the scene and, when confronted by a witness, offered money and attempted to bribe him to avoid reporting the crash.
A breath test showed a blood-alcohol content of approximately .237 percent; Bottcher later admitted he knew he had struck Saul.
Prior to the accident Bottcher had limited legal history but a long history of alcohol dependence and heavy drinking since adulthood.
Bottcher pleaded no contest to manslaughter, third-degree assault, and failure to render assistance; the superior court imposed a composite 23-year term with 3 years suspended and lifetime license revocation.
The Court of Appeals affirmed, and Bottcher sought Supreme Court review solely on the propriety of the lifetime license revocation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether lifetime license revocation is allowed	Bottcher argued fine distinction from chronic-offender standard applies.	State contends extreme-case standard justifies lifetime revocation.	Lifetime revocation upheld as not clearly mistaken.
Whether chronic-offender status is required for lifetime revocation	Fine’s chronic-offender language limits to chronic offenders.	Dodge permits lifetime revocation in extreme cases, not limited to chronic offenders.	Chronic-offender status is not a necessary predicate for lifetime revocation.
Whether the court applied the correct standard and supported it with facts	Record insufficiently shows extreme danger or rehabilitation risk.	Record showed extreme indifference and long-term alcohol dependence requiring revocation.	Superior court applied Dodge and based on facts supported lifetime revocation.

Dodge v. Municipality of Anchorage, 877 P.2d 270 (Alaska App. 1994) (lifetime revocation allowed for extreme cases to protect the public)
Fine v. State, 22 P.3d 20 (Alaska App. 2001) (limits lifetime revocation considerations to certain factual contexts)
Pears v. State, 698 P.2d 1198 (Alaska 1985) (discusses implications of changing mandatory minimums)
State v. Hodari, 996 P.2d 1230 (Alaska 2000) (establishes standard for evaluating revocation decisions under Alaska law)
McClain v. State, 519 P.2d 811 (Alaska 1974) (historical framing for extreme-indifference to life in homicide cases)
Bottcher v. State, Mem. Op. & J., 2009 WL 226010 (Alaska App. 2009) (prior appellate discussion of extreme-case standard in Bottcher’s context)