Jackson v. Municipality of Anchorage, 375 P.3d 1166

In July 2004 Anchorage Police seized Willie Jackson’s personal property (cash, coins, a 1990 Oldsmobile, a wedding ring, etc.) during arrests; the Oldsmobile was impounded and sold at auction in 2004.
Jackson was federally prosecuted; federal court ordered return/stay-of-forfeiture of property in 2006 and again directed return of the Oldsmobile and ring in May 2007; federal filings show APD possession and also indicate the car had been impounded in July 2004.
Jackson alleged the Municipality of Anchorage failed to return his property despite the federal orders; Assistant U.S. Attorneys later reported APD would apply remaining property toward a municipal debt.
Jackson filed a conversion suit against the Municipality in September 2012, nearly eight years after the 2004 seizure and about five years after the 2007 federal inventory order.
The Municipality moved to dismiss under Alaska Civ. R. 12(b)(6) as time-barred by the two-year statute of limitations (AS 09.10.070); the superior court granted dismissal, concluding Jackson should have discovered his claim by 2007.
The Alaska Supreme Court reversed, holding that the complaint’s factual allegations could support multiple accrual dates and that dismissal at the pleading stage was improper because inquiry-notice and reasonableness are fact-specific.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jackson’s conversion claim was time-barred under the two-year statute of limitations (discovery-rule accrual / inquiry notice)	Jackson argued federal orders and later federal communications kept the property under federal custody and that he was not put on inquiry notice of a claim against the Municipality until 2012; alternatively, discovery-rule tolling made his 2012 filing timely	Municipality argued Jackson knew (or reasonably should have known) of the claim by 2007 (per federal court orders saying he must contact APD), so the two-year limitation expired by 2009 and dismissal was proper	Reversed dismissal. Court held pleadings alleged facts supporting multiple possible accrual dates (2004, 2007, 2011, 2012) and that inquiry-notice and reasonableness are fact questions; Rule 12(b)(6) dismissal was improper and case remanded for further proceedings

John’s Heating Serv. v. Lamb, 129 P.3d 919 (Alaska 2006) (explains discovery rule accrual: cause of action accrues when plaintiff discovers or reasonably should have discovered all elements)
Gefre v. Davis Wright Tremaine, LLP, 306 P.3d 1264 (Alaska 2013) (discusses inquiry-notice as fact-specific and that discovery rule may yield multiple possible accrual dates)
Larson v. State, Dep’t of Corr., 284 P.3d 1 (Alaska 2012) (pleading standards on dismissal and treating allegations in plaintiff’s favor)
Cameron v. State, 822 P.2d 1362 (Alaska 1991) (reasonableness of inquiry is usually a factual question; sometimes discovery is necessary)
Pedersen v. Zielski, 822 P.2d 903 (Alaska 1991) (where plaintiff makes an inquiry, question becomes whether inquiry was reasonable)
Haakanson v. Wakefield Seafoods, Inc., 600 P.2d 1087 (Alaska 1979) (legislative purpose of statutes of limitation to bar stale claims)