Liz Vazquez, Chris Duke, Randy Eledge, Steve Strait, and Kathryn Werdahl v. Lt. Governor Nancy Dahlstrom, in her Official Capacity as Lt. Governor for the State of Alaska, Michaela Thompson, in her Official Capacity as Acting Director of the Division of Elections, and Jennie Armstrong, 544 P.3d 1178

Background

Jennie Armstrong moved from Louisiana to Alaska in May 2019, after starting a romantic relationship with Benjamin Kellie, an Alaska resident, and deciding during her visit to move in with him in Anchorage.
Armstrong briefly left Alaska after May 20, 2019, for prior commitments, but testified that her intent was to return and reside in Alaska.
She later obtained an Alaska driver's license, registered her business and to vote in Alaska, and built her life and family there.
In June 2022, Armstrong filed her candidacy for Alaska House District 16, declaring Alaska residency since May 20, 2019.
Her eligibility was challenged by her election opponent, Liz Vazquez, alleging Armstrong did not satisfy the three-year state residency requirement by the June 1, 2022, filing deadline.
The superior court found Armstrong became a resident on May 20, 2019; the Alaska Supreme Court affirmed, although on a different statutory basis.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which statute governs Alaska state residency for legislative eligibility	Only Title 15 election statutes control residency for candidates	Title 1 (general statutes) governs state residency, while Title 15 governs district/voter residency	Held: Title 1 determines Alaska state residency for this purpose
Date Armstrong established Alaska residency	Armstrong did not become a resident until June 7 or later, due to her departure and lack of commitment to state residency	Armstrong decided and intended to move to Alaska on May 20, 2019, which was sufficient despite temporary absence	Held: Armstrong established residency on May 20, 2019; absence was temporary and did not negate intent
Weight given to actions after forming intent to reside	Subsequent acts (marriage, licenses, etc.) should not control the date of establishing residency	Later acts support credibility of Armstrong’s stated intent to remain and make Alaska home	Held: Subsequent conduct is consistent and supports finding of intent as of May 20, 2019
Impact of inconsistencies in documentary evidence (e.g., fishing licenses, social media)	Inconsistencies in licenses and posts undermine Armstrong’s claimed date; court did not sufficiently consider indicia of implausibility	Inconsistencies explained by caution, different purposes (e.g., fishing license residency), and credibility findings; not dispositive	Held: Court credited Armstrong’s explanations and found no clear error; evidence did not undermine finding

Key Cases Cited

Lake & Peninsula Borough Assembly v. Oberlatz, 329 P.3d 214 (Alaska 2014) (establishing standards for evaluating residency and intent)
Sheffield v. Sheffield, 265 P.3d 332 (Alaska 2011) (deference to trial court’s credibility and factual findings)
Heller v. State, Dep't of Revenue, 314 P.3d 69 (Alaska 2013) (different definitions of residency in Alaska statutes)
Mouritsen v. Mouritsen, 459 P.3d 476 (Alaska 2020) (holistic approach to determining residency and intent)