Wielechowski v. State, 403 P.3d 1141

In 1976, Alaska voters amended the constitution to create the Permanent Fund and dedicate certain revenues to its principal; income was to be deposited in the general fund unless provided by law.
The anti-dedication clause originally prohibited revenue dedications, later amended by section 15 to permit specific Permanent Fund arrangements.
The Permanent Fund income is managed via the earnings reserve and can be appropriated by statute for dividends and related costs.
Since 1982, Permanent Fund income has generally flowed into the earnings reserve and then to a dividend program under statutory formula.
In 2016, the legislature appropriated a large transfer from the earnings reserve to the dividend fund, but the governor vetoed part of the transfer, reducing the payout.
A suit was filed challenging whether the 1976 amendment exempted Permanent Fund income from anti-dedication and whether the governor’s veto affected the transfer; the superior court ruled the transfer required an appropriation and veto compliance, which the court affirmed on alternative grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the 1976 amendment exempt Permanent Fund income from anti-dedication?	Wielechowski argues the amendment grants legislative dedication of earnings.	State argues the amendment only dedicates fund principal, not income, and does not exempt income from anti-dedication.	No exemption; income remains subject to appropriation.
Did Governor Walker validly veto the transfer amount from earnings reserve?	Wielechowski contends the governor overstepped by striking language that changed the appropriation.	State argues governor can strike or reduce appropriations but cannot distort legislative intent.	Governor validly exercised veto authority by reducing the transfer amount, without altering the purpose.

Malone v. Meekins, 650 P.2d 351 (Alaska 1982) (citing cases on constitutional budgeting and dedication principles)
State v. A.L.I.V.E. Voluntary, 606 P.2d 769 (Alaska 1980) (anti-dedication framework guidance)
Plumley v. Hale, 594 P.2d 497 (Alaska 1979) (budget and appropriation considerations)
K & L Distribs., Inc. v. Murkowski, 486 P.2d 351 (Alaska 1971) (anti-dedication and spending controls context)
State v. Planned Parenthood of Alaska, 171 P.3d 577 (Alaska 2007) (interpretation of constitutional provisions and budgeting constraints)
Hickel v. Cowper, 874 P.2d 922 (Alaska 1994) (earnings reserve availability for appropriation; budgeting construction)
Zobel v. Williams, 457 U.S. 55 (1982) (federal equal protection context for dividend program)
Sonneman v. Hickel, 836 P.2d 936 (Alaska 1992) (frame the anti-dedication purpose and budgeting discipline)
State v. Ketchikan Gateway Borough, 366 P.3d 86 (Alaska 2016) (anti-dedication clause interpretation and budgeting framework)