Chena Obstetrics and Gynecology and Dale Hardy CNM, and Banner Medical Group d/b/a Fairbanks Memorial Hospital and Tanana Valley Clinic v. Lauren Bridges, on behalf of S.B., her minor child, Fairbanks Memorial Hospital Tanana Valley Clinic Banner Health and Banner Health Physicians Alaska, LLC v. Lauren Bridges, on Behalf of S.B., her Minor Child Chena Obstetrics and Gynecology and Dale Hardy C.N.M., 502 P.3d 951

In 2010 S.B. was born with severe, permanent neurological injuries; her mother Lauren Bridges sued multiple health-care providers (midwife Dale Hardy; Chena Obstetrics & Gynecology; Banner Medical Group).
Bridges’s out-of-state counsel appeared pro hac vice; they missed response deadlines to defendants’ summary judgment motions and filed late or deficient oppositions and discovery responses.
The superior court granted summary judgment to Hardy/Chena and Banner and then entered final judgment for all defendants; Bridges moved under Alaska R. Civ. P. 60(b) for relief.
Bridges argued Rule 60(b)(1) (excusable neglect) and alternatively Rule 60(b)(6) (extraordinary injustice), submitting late expert affidavits; the superior court found counsel’s neglect inexcusable but nevertheless granted relief under 60(b)(6).
The defendants sought review. The Alaska Supreme Court affirmed denial of 60(b)(1) relief, reversed the 60(b)(6) grant, and held that attorney neglect—except abandonment—cannot justify 60(b)(6) relief; the case was remanded to enter judgment for defendants.

Issue	Bridges' Argument	Defendants' Argument	Held
Whether counsel’s missed deadlines constituted "excusable neglect" under Rule 60(b)(1)	Missed calendar entry and procedural unfamiliarity made the failures excusable; late affidavits were promptly filed	Counsel’s explanations were inconsistent, unsworn, and insufficient; local counsel should have corrected errors	Court: No abuse of discretion in finding neglect inexcusable; 60(b)(1) relief denied
Whether an "injustice exception" permits 60(b)(1) relief for inexcusable attorney neglect	Even if neglect was inexcusable, denying relief would produce injustice because plaintiff has expert evidence creating material fact disputes	Rule 60(b)(1) requires excusable neglect; injustice does not substitute for that requirement	Court: No; movant must show excusable neglect; no separate injustice exception to relieve inexcusable neglect under 60(b)(1)
Whether Rule 60(b)(6) authorizes relief for attorney neglect (including gross neglect)	Relief under 60(b)(6) is available to avoid injustice and to allow merits adjudication; federal cases permit relief for gross attorney neglect	Mutual exclusivity bars using clause (6) for matters covered by clauses (1)-(5); attorney neglect without abandonment cannot satisfy (6)	Court: Clause (6) cannot be used to excuse ordinary or inexcusable attorney neglect; only attorney conduct amounting to abandonment can permit 60(b)(6) relief; superior court erred in granting relief here

Erica G. v. Taylor Taxi, Inc., 357 P.3d 783 (Alaska 2015) (adopts an "excusable neglect" standard requiring neglect plus a valid excuse causally connected to the missed act)
Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (U.S. 1993) (describes "excusable neglect" as an elastic concept to be assessed case-by-case)
Farrell ex rel. Farrell v. Dome Labs., Inc., 650 P.2d 380 (Alaska 1982) (discusses attorney errors and mutual exclusivity of Rule 60(b); ties injustice language to clause (1))
O’Link v. O’Link, 632 P.2d 225 (Alaska 1981) (applies mutual exclusivity and analyzes attorney mistake under clause (6) as not extraordinary)
Rill v. State, Dep’t of Highways, 669 P.2d 573 (Alaska 1983) (Justice Rabinowitz’s dissent discusses attorney abandonment as possible basis for relief; majority cautious)
Cmty. Dental Servs. v. Tani, 282 F.3d 1164 (9th Cir. 2002) (Ninth Circuit: gross attorney negligence that amounts to effective abandonment can justify relief under Rule 60(b)(6))
Link v. Wabash R.R. Co., 370 U.S. 626 (U.S. 1962) (principle that clients typically are bound by actions of their chosen counsel)
Hartland v. Hartland, 777 P.2d 636 (Alaska 1989) (clause (6) is reserved for extraordinary circumstances not covered by preceding clauses)
Neilson v. Neilson, 914 P.2d 1268 (Alaska 1996) (attorney neglect generally falls under clause (1); time-bar may preclude clause (1) relief)