State v. Fyfe

[CRIMINAL LAW]

In State v. Fyfe,[1] the supreme court held that, while criminal traffic offenses are subject to the doubling of fines or maximum fines if the offense occurs in a traffic safety corridor or highway work zone, such doubling does not apply to the minimum fine for an offense.[2] Fyfe was convicted of felony driving under the influence of alcohol and received the mandatory minimum $10,000 fine for driving through a designated traffic safety corridor at the time of the offense.[3] Because Alaska law imposes a mandatory doubling of certain fines when the traffic offense in question occurs in a traffic safety corridor or work zone, the superior court doubled Fyfe’s fine.[4] Fyfe appealed, arguing that the legislature did not intend to double fines for felonies.[5] The court of appeals reversed the doubled fine, agreeing that the legislative history of the traffic safety statute precluded its application to criminal offenses.[6] The supreme court held that the plain meaning of the traffic safety statute applies to any instance where a person violates one its provisions, including by criminal traffic offense.[7] The court noted that the legislative history of the statute—including decisions not to narrow the statute’s scope and ambiguous evidence as to whether the statute meant to address drunk driving—did not weigh convincingly against this plain meaning.[8] However, the court held that, even though the statute applies to criminal traffic offenses, the fines which may be doubled are limited to any statutorily set or maximum fines—not the minimum fine.[9] The court also noted that the statute specifies that the fine or maximum fine may be doubled; this specific, disjunctive language would become superfluous if the statute was also applied to minimum fines.[10] Further, the court held that the “maximum fine” language was intended to assure judges that, under the traffic safety statute, they may increase fines above the otherwise imposed cap, whereas judges already have discretion to increase fines where only a minimum fine is statutorily imposed.[11] Affirming the court of appeals but rejecting its reasoning, the supreme court held that while criminal traffic offenses are subject to the doubling of set or maximum fines if the offense occurs in a traffic safety corridor or highway work zone, such doubling does not apply to the minimum fine for an offense.[12]

[1] 370 P.3d 1092 (Alaska 2016).

[2] Id. at 1094.

[3] Id.

[4] Id.

[5] Id.

[6] Id.

[7] Id. at 1095.

[8] Id. at 1096-99.

[9] Id. at 1101.

[10] Id. at 1099-1100.

[11] Id. at 1101.

[12] Id. at 1099, 1101.

State v. Fyfe

[CRIMINAL LAW]

In State v. Fyfe,[1] the supreme court held that, while criminal traffic offenses are subject to the doubling of fines or maximum fines if the offense occurs in a traffic safety corridor or highway work zone, such doubling does not apply to the minimum fine for an offense.[2] Fyfe was convicted of felony driving under the influence of alcohol and received the mandatory minimum $10,000 fine for driving through a designated traffic safety corridor at the time of the offense.[3] Because Alaska law imposes a mandatory doubling of certain fines when the traffic offense in question occurs in a traffic safety corridor or work zone, the superior court doubled Fyfe’s fine.[4] Fyfe appealed, arguing that the legislature did not intend to double fines for felonies.[5] The court of appeals reversed the doubled fine, agreeing that the legislative history of the traffic safety statute precluded its application to criminal offenses.[6] The supreme court held that the plain meaning of the traffic safety statute applies to any instance where a person violates one its provisions, including by criminal traffic offense.[7] The court noted that the legislative history of the statute—including decisions not to narrow the statute’s scope and ambiguous evidence as to whether the statute meant to address drunk driving—did not weigh convincingly against this plain meaning.[8] However, the court held that, even though the statute applies to criminal traffic offenses, the fines which may be doubled are limited to any statutorily set or maximum fines—not the minimum fine.[9] The court also noted that the statute specifies that the fine or maximum fine may be doubled; this specific, disjunctive language would become superfluous if the statute was also applied to minimum fines.[10] Further, the court held that the “maximum fine” language was intended to assure judges that, under the traffic safety statute, they may increase fines above the otherwise imposed cap, whereas judges already have discretion to increase fines where only a minimum fine is statutorily imposed.[11] Affirming the court of appeals but rejecting its reasoning, the supreme court held that while criminal traffic offenses are subject to the doubling of set or maximum fines if the offense occurs in a traffic safety corridor or highway work zone, such doubling does not apply to the minimum fine for an offense.[12]

[1] 370 P.3d 1092 (Alaska 2016).

[2] Id. at 1094.

[3] Id.

[4] Id.

[5] Id.

[6] Id.

[7] Id. at 1095.

[8] Id. at 1096-99.

[9] Id. at 1101.

[10] Id. at 1099-1100.

[11] Id. at 1101.

[12] Id. at 1099, 1101.