District Court, D. Alaska — appointed by John F. Kennedy
Hjelle v. Brooks
District Court, D. Alaska · 1976-06-11 · cited 5×
The case involved a group of commercial king crab fishermen seeking to block Alaska from enforcing state fishing regulations in the Bering Sea beyond three miles from the coast. After prior regulations were enjoined, the state repealed them, adopted new ones, and filed criminal charges against seven of the plaintiffs, leading to a state supreme court decision upholding the regulations' constitutionality. The federal court dismissed the action as to all plaintiffs and claims, relying on Younger abstention principles applicable to pending state criminal prosecutions. It imputed the state proceedings to the remaining federal plaintiffs due to their joint activity and common interest through industry associations, and treated the challenge to the new regulations as equivalent to a new claim that warranted deference to the state process.
criminal lawfederal powerenvironmentbusiness & regulatory
United States v. Krell
District Court, D. Alaska · 1975-02-19 · cited 10×
In United States v. Krell, defendants were charged with possession of controlled substances after drugs were discovered in a package shipped by air from Portland to Anchorage. The court addressed a motion to suppress evidence under Fed.R.Crim.P. 41(e), focusing on the initial search of the package by airline employees in the presence of police officers, the subsequent retrieval of the package, and the search of one defendant's purse. The court granted the motion, ruling that the airport search was subject to the Fourth Amendment because the employees' sole purpose was to aid law enforcement in locating drugs, making it not a purely private search. As a result, the evidence obtained at the airport and all derivative evidence, including from later searches, were suppressed as fruits of the illegal search.
criminal lawprocedure
Hjelle v. Brooks
District Court, D. Alaska · 1974-04-30 · cited 16×
The case involved Washington crab fishermen challenging Alaska regulations that set an annual quota for king crab in the Bering Sea Shellfish Area and barred the transport or sale of crab taken in violation of those rules even from waters beyond Alaska's territorial limits. Plaintiffs sought declaratory and injunctive relief on constitutional grounds, leading to the convening of a three-judge district court. The court confirmed its jurisdiction under 28 U.S.C. § 2281 because the regulations effected statewide policy and the constitutional claims were substantial, then granted a preliminary injunction against enforcement. The core reasoning was that Alaska could not extend its regulatory authority to the high seas above the outer continental shelf, as federal law and international principles limit state jurisdiction to territorial waters.
business & regulatoryfederal power
Gibson v. Alaska Alcoholic Beverage Control Board
District Court, D. Alaska · 1974-04-05 · cited 12×
This case concerned whether a liquor license used as collateral for a Small Business Administration loan could be transferred to the SBA after the borrower defaulted on the loan. The Alaska Alcoholic Beverage Control Board had approved the transfer, which the borrower challenged on the grounds that the license was a non-transferable personal privilege rather than property. The court, applying Alaska state law including the Uniform Commercial Code, held that the license qualified as property subject to a security interest and could be transferred pursuant to the security agreement. It distinguished this situation from cases involving privileges between a license holder and the Board, granted summary judgment to the SBA, and rejected arguments based on exemption statutes or limits on the SBA's authority.
business & regulatoryproperty
Krall v. Royal Inns of America, Inc.
District Court, D. Alaska · 1973-12-03 · cited 5×
This case arose from a construction worker's personal injury when he fell and grabbed a hoist guide while working on an Anchorage hotel project, where the hoist lacked required walkways, guardrails, and toeboards in violation of the Alaska General Safety Code; the defendant controlled the leased hoist. The court had previously ruled the defendant's use of the hoist constituted negligence per se that proximately caused the injury. On the plaintiff's motion for summary judgment, the issue was whether contributory negligence could still be raised as a defense to that negligence per se claim based on the safety code violations. The court denied the motion and held that contributory negligence remains an available affirmative defense, reasoning that the Alaska statutes provided only for fines and penalties without any indication of legislative intent to eliminate the defense or place entire responsibility on employers, and that federal courts in diversity must follow the rule the state supreme court would likely adopt.
torts & liabilitylabor & employment
Anderson v. Fairchild Hiller Corporation
District Court, D. Alaska · 1973-10-25 · cited 15×
This case involved a plaintiff who suffered personal injuries in 1969 after contacting the tail rotor of a helicopter made by the defendant manufacturer; the plaintiff, an employee of a company that used the helicopter, sued on theories of negligence, strict liability, and breach of implied warranty of merchantability. The court granted the defendant's motion for summary judgment, holding that the negligence and strict liability claims were time-barred by Alaska's two-year statute of limitations for personal injury actions and that the warranty claim could not proceed due to lack of privity between the plaintiff and defendant. The court reasoned that strict liability claims are governed by the tort statute of limitations rather than the UCC's four-year contract period because they do not require a contract, cannot be disclaimed, and fall under the residual personal injury limitations provision, while privity remains necessary for warranty claims under Alaska precedent even though strict liability offers an alternative remedy for injured parties without it.
torts & liabilityprocedure