In Doan v. Banner Health, 485 P.3d 537 (Alaska 2021), the supreme court held that settlement funds may be withheld for non-settling defendants’ eventual attorneys’ fees; however, the court also held that reserved settlement funds may be partially distributed for the payment of plaintiff’s attorneys’ fees. (Id. at 542–45). In 2013, Doan’s estate brought a wrongful death suit against seven defendants, resulting in a settlement with two defendants in 2018. (Id. at 539). Doan’s estate requested the immediate distribution of that settlement for the payment of attorney’s fees and the establishment of a trust for the estate’s beneficiary; the non-settling defendants requested that the court deny any distribution, reserving the settlement to pay their attorneys’ fees should they prevail in subsequent proceedings. (Id. at 539–40). The superior court ordered that the settlement be applied to the estate’s attorneys’ fees, but that the remainder be reserved. (Id. at 540). In response, the estate appealed for the distribution of the entire settlement, while the non-settling defendants appealed for the reservation of the entire settlement. (Id.). The supreme court first found that because Doan’s estate was representing Doan’s beneficiary, the defendants, should they prevail, may only seek attorneys’ fees from a reserved settlement fund. (Id. at 542). Therefore, the settlement fund must be reserved to make the defendant’s recovery possible. (Id.). However, the court also found that because the reserved settlement fund only exists due to the Doan estate and its attorney, it would be unjust to prevent the estate from paying its attorney through that fund. (Id. at 543–44). To find otherwise, the court held, would unjustly enrich the non-settling defendants at the expense of the Doan estate. (Id.). Affirming the superior court, the supreme court held that courts may withhold settlement funds for the potential payment of non-settling defendant’s attorneys’ fees but may also partially distribute reserved settlement funds for the payment of a plaintiff’s attorneys’ fees. (Id. at 542–45).