GOVERNMENT
Supreme Court of Alaska (2023)
Kubi Johnson
In Pruitt v. State, 526 P.3d 136 (Alaska 2023), the supreme court held Pruitt asserted nonfrivolous constitutional claims and remanded for further proceedings on whether sanctions are proper. Lance Pruitt lost a close election to Elizabeth Snyder. (Id. at 138). Pruitt sued the State alleging it failed to ensure a fair election. (Id.). Elizabeth Snyder intervened, and the superior court dismissed Pruitt’s claim. (Id. at 138–39). The superior court granted attorney’s fees to Snyder. (Id. at 141). On appeal, Pruitt argued the superior court erred in awarding attorney’s fees because he asserted nonfrivolous constitutional claims, and the superior court did follow proper sanctions procedures. (Id.). The supreme court agreed. (Id.). The supreme court reasoned Pruitt’s claim arose from a constitutional right—the right to vote— and it was not frivolous. (Id. at 142). The superior court erred because nonfrivolous constitutional claims are protected from adverse award of attorneys’ fees. (Id. at 142–43). However, the fees could qualify as sanctions. (Id. at 143). On this issue, the superior court also erred because Snyder did not motion for sanctions per Rule 37(c) and Pruitt did not have an opportunity to be heard. (Id. at 144–45). Accordingly, the supreme court held Pruitt asserted nonfrivolous constitutional claims and remanded the case for further proceedings on whether sanctions are proper. (Id. at 138).
