Supreme Court of Alaska (2022)
In Fairbanks North Star Borough v. Victory Ministries of Alaska, Inc., 515 P.3d 111 (Alaska 2022), the supreme court held that a court no longer has subject matter jurisdiction when the court closes the initial case and another case based on the same underlying controversy begins. (Id. at 115–116). A borough revoked a ministry’s tax-exempt status after discovering that it leased its extensive camp properties to the public, operating a retreat center and vacation rental business. (Id. at 113–114). The ministry appealed this revocation to superior court, and the superior court dismissed the case, determining the case should be before an administrative board. (Id. at 114). The superior court later reconsidered this dismissal, remanding the case to the borough tax assessor. (Id.). The parties also settled, agreeing to let the assessor take new evidence and make detailed findings, but leaving open the option to appeal the assessor’s determination. (Id.). When the borough assessor released its findings, the ministry appealed this new determination, and the appeal received a new case number. (Id.). Yet the court, of its own accord, ruled on the old, remanded and settled case, finding the borough did not support the tax exemption revocation with sufficient evidence. (Id. at 115). The borough appealed this decision to the supreme court, which applied the subject matter jurisdiction doctrine, a rule stating that courts can only hear certain types of cases. (Id. at 115). After a court “enters its judgement,” the court’s jurisdiction ends; the court cannot “retain it in perpetuity.” (Id.). Rejecting the ministry’s argument that a motion to enforce the superior court’s final order allowed the court to recover its jurisdiction, the supreme court determined that jurisdiction ended when the court remanded the case, noting that a court can only recover its jurisdiction if “mistake, inadvertence, fraud, prematurity, or misapprehension” occurred, as all litigants have a great interest in “repose.” (Id. at 116). Additionally, by ignoring the new facts the assessor discovered in its later investigation, the court may have violated the borough’s due process right. (Id. at 116–117). Vacating the lower court’s decision, the supreme court held that a court no longer has subject matter jurisdiction when the court closes the initial case and another case based on the same underlying controversy is ongoing. (Id. at 115–117).