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Jouppi v. State

CONSTITUTIONAL LAW
Supreme Court of Alaska (2025)
Tommy Nowak

In Jouppi v. State, 566 P.3d 943 (Alaska 2025), the Supreme Court of Alaska held that it was not unconstitutionally excessive punishment to confiscate the airplane of a pilot who attempted to transport alcohol into a dry village. (Id. at 947–48). Jouppi, the owner of a private airline company, attempted to fly a passenger into a village that prohibited the sale, consumption, and possession of alcohol. (Id. at 948). The passenger brought 3 cases of alcohol on board. (Id. at 948). At trial, it was found that Jouppi noticed at least one six-pack of beer. (Id. at 948). Before the plane took off, the alcohol was found and seized by state troopers. (Id. at 949). As part of his criminal punishment, Jouppi had to forfeit the airplane used in the commission of the offense. (Id. at 949). He challenged this punishment as “unconstitutionally excessive” under the Eighth Amendment. (Id. at 949). The trial court held that the punishment was unconstitutionally excessive because it was grossly disproportionate to the gravity of the offense committed. (Id. at 950). The Court of Appeals remanded to the trial court to conduct additional fact-finding. (Id. at 950). The State appealed to the Alaska Supreme Court, arguing that regardless of the findings of the lower court, Jouppi’s punishment was not grossly disproportionate to his offense. (Id. at 951). The Supreme Court agreed with the State, noting that the legislature is primarily responsible for determining the appropriateness of penalties and that because judicial assessments are imprecise, the Courts should defer to the legislature’s judgment. (Id. at 953–54). The Court was persuaded by the fact that the statute was amended in 2004 to mandate the forfeiture of aircraft used to unlawfully import alcohol into dry communities due to studies indicating the damage caused by excessive alcohol consumption. (Id. at 955–56). The Court also noted that gross disproportionality challenges should “rarely succeed” (Id. at 954). Reversing the Court of Appeals’ decision, the Supreme Court held that the statutory punishment requiring forfeiture of aircraft involved in transporting alcohol into dry communities was not unconstitutionally excessive. (Id. at 958).

Jouppi v. State

CONSTITUTIONAL LAW
Supreme Court of Alaska (2025)
Tommy Nowak

In Jouppi v. State, 566 P.3d 943 (Alaska 2025), the Supreme Court of Alaska held that it was not unconstitutionally excessive punishment to confiscate the airplane of a pilot who attempted to transport alcohol into a dry village. (Id. at 947–48). Jouppi, the owner of a private airline company, attempted to fly a passenger into a village that prohibited the sale, consumption, and possession of alcohol. (Id. at 948). The passenger brought 3 cases of alcohol on board. (Id. at 948). At trial, it was found that Jouppi noticed at least one six-pack of beer. (Id. at 948). Before the plane took off, the alcohol was found and seized by state troopers. (Id. at 949). As part of his criminal punishment, Jouppi had to forfeit the airplane used in the commission of the offense. (Id. at 949). He challenged this punishment as “unconstitutionally excessive” under the Eighth Amendment. (Id. at 949). The trial court held that the punishment was unconstitutionally excessive because it was grossly disproportionate to the gravity of the offense committed. (Id. at 950). The Court of Appeals remanded to the trial court to conduct additional fact-finding. (Id. at 950). The State appealed to the Alaska Supreme Court, arguing that regardless of the findings of the lower court, Jouppi’s punishment was not grossly disproportionate to his offense. (Id. at 951). The Supreme Court agreed with the State, noting that the legislature is primarily responsible for determining the appropriateness of penalties and that because judicial assessments are imprecise, the Courts should defer to the legislature’s judgment. (Id. at 953–54). The Court was persuaded by the fact that the statute was amended in 2004 to mandate the forfeiture of aircraft used to unlawfully import alcohol into dry communities due to studies indicating the damage caused by excessive alcohol consumption. (Id. at 955–56). The Court also noted that gross disproportionality challenges should “rarely succeed” (Id. at 954). Reversing the Court of Appeals’ decision, the Supreme Court held that the statutory punishment requiring forfeiture of aircraft involved in transporting alcohol into dry communities was not unconstitutionally excessive. (Id. at 958).