In Robinson v. Alaska Housing Finance Corporation,[1] the supreme court held that claims for wrongful termination of a lease are barred by res judicata if parties have agreed to dismiss an earlier claim with prejudice. The Robinsons participated in a federal housing voucher program through the Alaska Housing Finance Corporation (AHFC) which paid for part of their rent. This voucher was terminated per AHFC guidelines after the landlord was awarded a judgment against the Robinsons for damaging the apartment. The Robinsons appealed this termination in superior court but both parties agreed to dismiss the claim with prejudice. As a result of the voucher’s termination, the Robinsons were evicted from their housing and brought a claim against AHFC for wrongful termination of the voucher and failure to provide due process. The supreme court held that both of these claims were barred by res judicata. Res judicata is meant to prevent re-litigation of claims that have reached a proper final judgment. The claim of wrongful termination reached a final conclusion when the Robinsons first brought the claim and agreed with AHFC to dismiss the claim with prejudice. This settlement fulfills the final judgment on the merits requirement and thus, Robinsons had waived their claims. Affirming the lower court’s decision, the supreme court held that claims for wrongful termination of a lease are barred by res judicata if parties have agreed to dismiss an earlier claim with prejudice.
[1] 442 P.3d 763 (Alaska 2019).