O'CONNELL v. Will, 263 P.3d 41

O'Connell obtained a judgment against the Wills in 2002 for $7,000 on the note plus $6,492.50 in attorney's fees and $219.86 in costs.
The promissory note (signed 1999) required the Wills to pay a defaulted installment and, in case of suit, to pay a reasonable attorney's fee in the action.
After collection efforts, Anthony Will paid the judgment following garnishment and asset searches.
In 2009 Anthony Will moved for an order that the judgment had been satisfied; the superior court granted the motion.
O'Connell sought additional post-judgment attorney's fees incurred in collecting the judgment, which the superior court denied.
On appeal, the Alaska Supreme Court reversed, holding the contract allowed post-judgment attorney's fees and vacated the satisfaction order, remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service defects bar consideration of the motion	O'Connell	Will	No abuse; motion considered despite service defect
Whether O'Connell may recover post-judgment attorney's fees under the note	O'Connell	Will	Yes; contract permits post-judgment fees for collection of the note
Interpretation of the note's attorney's fees provision	O'Connell	Will	Plain language includes post-judgment enforcement fees

Gamble v. Northstore Partnership, 28 P.3d 286 (Alaska 2001) (fee shifting at all court levels when contract contemplates shifting fees)
Rockstad v. Erikson, 113 P.3d 1215 (Alaska 2005) (attorney's fees clause includes post-judgment proceedings when intended)
Murat v. F/V Shelikof Strait, 793 P.2d 69 (Alaska 1990) (abuse-of-discretion standard for defective service; service on a party may be sufficient depending on circumstances)
Torrey v. Hamilton, 872 P.2d 186 (Alaska 1994) (Rule 82 limitations; post-judgment fees generally governed by contract or rule)
Estate of Polushkin ex rel. Polushkin v. Maw, 170 P.3d 162 (Alaska 2007) (interpretation of contract terms within Alaska’s framework for fees)