In State v. Tofelogo, the supreme court held that the domestic violence aggravating factor has broad applicability in determining the sentencing of a guilty individual. Teila Tofelogo accidentally stabbed his sober living group home roommate, Dennis Fathke, after horse-playing with a knife. Tofelogo pled guilty to negligent homicide and stipulated to the applicability of the aggravating factor that the offence “was committed against a spouse, a former spouse, or a member of the social unit made up of those living together in the same dwelling as the defendant.” Tofelogo was sentenced to six years imprisonment, a sentence that was longer than presumptive range for a first felony negligent homicide due to the aggravating factor. Tofelogo appealed this sentence claiming the aggravator was inappropriate and the court of appeals reversed reasoning that the aggravator was intended to apply to domestic violence situations where the relationship between the victim and defendant is a component behind the offence. The supreme court held that this aggravator has broad applicability beyond just relationship-based domestic violence. The aggravator’s plain language clearly applies to offenses against roommates because a roommate is “a member of the social unit made up of those living together in the same dwelling.” This meaning was not contradicted by the legislative purpose of the statute. Thus, the supreme court held that the superior court did not err in giving the aggravator some weight in determining Tofelogo’s sentence because the domestic violence aggravator has broad applicability.
 44 P.3d 151 (Alaska 2019).