ADMINISTRATIVE LAW
Mike Keramidas
West v. Alaska Mental Health Trust Authority
In West v. Alaska Mental Health Tr. Auth., 467 P.3d 1064 (Alaska 2020), the supreme court held that the Land Office of the Alaska Mental Health Trust Authority acted in the Trust’s best interest when it sold five lots of land. (Id. at 1066). Louis and Stacy Oliva made an offer to purchase five lots from the Trust Authority and to also “pay reasonable compensation” for past use of one of the lots. (Id. at 1067). West also made an offer for only two lots and asked to purchases only a subdivision of one of them. (Id.). The Land Office accepted Oliva’s proposal over West’s, finding it to be “in the best interest of the Trust.” (Id.). The superior court rejected West’s argument that the Land Office did not act in its best interest because West failed to show how his offer would have provided a better return than Oliva’s. (Id. at 1068). The supreme court reviewed this administrative appeal using the reasonable basis standard to determine if the agency’s decision was supported by facts and was reasonable. (Id. at 1069). The court held that the Land Office’s sale was in the Trust’s best interest because the sale to Oliva would maximize long-term revenue. (Id. at 1070). The court relied on the fact that the Land Office received over $17,000 more than forecasted through the Oliva sale and that West showed little evidence to support his argument that his offer would have provided more revenue. (Id. at 1071). Affirming the superior court, the supreme court held that the Land Office of the Alaska Mental Health Trust Authority acted in the Trust’s best interest when it sold five lots of land to Oliva. (Id. at 1071).
