In Anderson v. State, Department of Administration,[1] the supreme court upheld the superior court’s finding that a suit was barred by the doctrine of laches as it was brought after an unreasonable delay that would cause the Department of Motor Vehicles (DMV) undue prejudice. In 1992, Anderson replaced his California driver’s license, which contained a motorcycle endorsement, with an Alaska driver’s license. Fifteen years later in 2007, Anderson discovered that contrary to his belief, his motorcycle endorsement had not transferred from his California license to his Alaska license. Although Anderson claimed that this was an error on the DMV’s part, the DMV refused to issue him a new motorcycle endorsement until he completed the necessary procedures. Anderson refused to take the necessary steps, and instead brought this suit in 2017, requesting that the court mandate that the DMV automatically restore his motorcycle endorsement. The superior court dismissed the case on multiple grounds, including that the claim was barred by the doctrine of laches. On appeal, the supreme court stated that the equitable defense of laches requires both an unreasonable delay by the party bringing the claim and an undue burden or prejudice caused by that unreasonable delay. The court found that while it could be possible that the initial fifteen year delay was reasonable, waiting to file the suit ten years after the discovery undoubtedly constituted an unreasonable delay. The court further held that this unreasonable delay would unduly prejudice the DMV, which, as directed by statute, destroys inactive records after fifteen years, and thus would have no evidence regarding the issue. The supreme court upheld the superior court’s finding that a suit was barred by the doctrine of laches as it was brought after an unreasonable delay that would cause the DMV undue prejudice.
[1] 440 P.3d 217 (Alaska 2019).
