Larson v. State, Department of Corrections
284 P.3d 1
| Alaska | 2012Background
- Larson, a pro se inmate at Spring Creek Correctional Center, filed two complaints alleging constitutional rights violations.
- First claim: paruresis and allegedly inadequate accomodations for urinalysis testing violated Eighth Amendment and state constitutional rights; sought declaratory, injunctive relief and costs.
- Second claim: revised visitor form for minors allegedly violated Larson’s state right to rehabilitation by being more restrictive than 22 AAC 05.130; sought declaratory and injunctive relief, and damages.
- Superior court dismissed both complaints under Rule 12(b)(6) for failure to state a claim, and later dismissed the state claim under Hertz v. Beach.
- Alaska appellate court consolidated the appeals to address proper Rule 12(b)(6) evaluation for pro se prisoners and reversed the dismissals, remanding for further proceedings.
- Court reiterates liberal construction of pro se pleadings and disfavors dismissal under Rule 12(b)(6).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Larson named a proper defendant under §1983 | Larson should be allowed to amend to name a proper defendant | State argued only that the wrong defendant was named, not substance | Remand for amendment and reconsideration; §1983 claim viability not foreclosed. |
| Whether Hertz bars private action under Alaska Constitution for damages | Hertz does not bar injunctive/declaratory relief | Hertz bars private damages under Alaska Constitution | Hertz does not preclude relief; remand for further proceedings on merits. |
| Standing to challenge revised visitation form under state constitution | Larson has a personal stake due to impact on visitation | Larson lacks standing | Larson has standing; remand for merits. |
| Collateral estoppel as to damages claim under Alaska Constitution | Prior case collaterally estops damages claim | Issues not identical; estoppel applies in limited contexts | Collateral estoppel not applicable; damages relief possible if other standards met. |
Key Cases Cited
- Hertz v. Beach, 211 P.3d 668 (Alaska 2009) (private damages under Alaska Constitution limited; injunctive relief available)
- Hertz v. Beach (quoted), 211 P.3d 668 (Alaska 2009) (standing and relief principles under Alaska Constitution)
- Bowers Office Prods., Inc. v. Univ. of Alaska, 755 P.2d 1095 (Alaska 1988) (standing; administrative review via declaratory relief possible)
- Kleven v. Yukon-Koyukuk Sch. Dist., 853 P.2d 518 (Alaska 1993) (standing; employee grievance procedures)
- Shooshanian v. Wagner, 672 P.2d 455 (Alaska 1983) (Rule 12(b)(6) with attachments considered; disfavor of dismissal)
- Dworkin v. First Nat'l Bank of Fairbanks, 444 P.2d 777 (Alaska 1968) (attachments to complaint treated as part of pleadings)
- Will v. Michigan Dep't of State Police, 491 U.S. 58 (1989) (gives framework for §1983 standing and official-capacity injunctive relief)
- Martin v. Mears, 602 P.2d 421 (Alaska 1979) (general Rule 12(b)(6) standards and relief)
- Guerrero v. Alaska Hous. Fin. Corp., 6 P.3d 250 (Alaska 2000) (construction of Alaska constitutional rights and remedies)
- Kaiser v. Umialik Ins., 108 P.3d 876 (Alaska 2005) (treatment of attachments and summary judgment conversion)