In Williams v. Baker, the supreme court held that an individual did not have an indirect fiduciary duty and thus the superior court erred when it shifted the burden to her to prove that she had not committed fraud under Alaska’s Unfair Trade Practice and Consumer Protection Act (UTPA). Johnny Williams provided financial services, such as payroll services and tax preparation, to plaintiff Violeta Baker for over five years. Johnny had full access to Baker’s checking account and had the power to write checks in her name. During this time, defendant Deverette Williams, Johnny’s wife who was not employed by Johnny, would occasionally record messages from Baker and deliver them to Johnny. Following an audit which revealed major discrepancies in her records, Baker filed a suit against both Johnny and Deverette, claiming that they both owed her a fiduciary duty and had committed fraud under the UTPA. After shifting the burden of proof to the Williams based on a finding that Johnny had a direct fiduciary duty and Deverette had an indirect fiduciary duty, the superior court found in favor of Baker and awarded her trebled damages under the UTPA. On appeal from Deverette after the death of Johnny, the supreme court found that Deverette did not owe an indirect fiduciary duty to Baker. Because she was not an “agent” of Johnny’s and in the absence of any special circumstances that would typically indicate a fiduciary relationship, the superior court erred in shifting the burden of proof to Deverette. Reversing the superior court’s conclusion of fraud under the UTPA and holding that Deverette is not subject to the UTPA, the supreme court remanded the case back to the superior court with the burden of proof back on Baker.
 446 P.3d 336 (Alaska 2019)