The Happy Farmer, LLC d/b/a Releaf Alaska v. Alaska State Fair, Inc.
497 P.3d 468
| Alaska | 2021Background
- Releaf (vendor) contracted with Alaska State Fair (Fair) for indoor booth space during the 2017 Palmer fair; the vendor handbook warned vendors to insure merchandise and stated in bold that the Fair "takes no responsibility for theft, loss, or vandalism."
- Fair provided 24-hour security that locked and unlocked the building nightly; Releaf left merchandise overnight in its booth inside locked display cases for which Releaf retained the only keys.
- An unknown intruder broke into the building overnight and stole a substantial amount of Releaf’s merchandise.
- Releaf sued Fair for breach of contract and for bailment (constructive and implied-in-fact); Releaf did not press an express-bailment theory and did not appeal the contract ruling.
- The superior court granted summary judgment to Fair on both the breach and bailment claims; Releaf appealed only the superior court’s rejection of its constructive and implied bailment theories.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constructive bailment: whether law should impose a bailment because Fair came into possession of merchandise | Releaf: Fair’s overnight control of building/security and permitting vendors to leave goods creates a constructive bailment | Fair: It never acquired possession of the goods; Releaf retained control (locked cases, sole keys) and handbook disclaimed responsibility | No constructive bailment; Fair never lawfully possessed Releaf’s goods such that law should impose a custodial duty |
| Implied-in-fact bailment: whether surrounding facts imply a bailment contract | Releaf: Allowing overnight storage, providing security, and controlling building keys imply an understanding that Fair would safeguard merchandise | Fair: No noncontractual conduct created an understanding; Releaf retained exclusive control of merchandise and paid no storage fee | No implied bailment; undisputed facts show Fair did not exercise exclusive possession, control, and dominion over the merchandise |
Key Cases Cited
- Alaska Constr. Equip., Inc. v. Star Trucking, Inc., 128 P.3d 164 (Alaska 2006) (defining bailment)
- J.P. Enterprises v. Ursin Seafoods, Inc., 777 P.2d 1165 (Alaska 1989) (bailee found where owner relinquished exclusive possession, custody, and control)
- Arnoult v. Webster, 480 P.3d 592 (Alaska 2020) (summary judgment reviewed de novo)