ADMINISTRATIVE LAW
Supreme Court of Alaska (2025)
Lily Skopp
In Rivera v. State, Department of Administration, Division of Motor Vehicles, 564 P.3d 1040 (Alaska 2025), the Supreme Court of Alaska determined that a driver whose license has been revoked in another state cannot obtain a new driver’s license in Alaska while that revocation is still in effect. (Id. at 1044). The Court upheld the Alaska Division of Motor Vehicles (DMV) decision to deny Joseph Rivera’s application for an Alaska driver’s license (Id.). Rivera’s license was revoked permanently in New York after three alcohol-related offenses, and the Alaska DMV denied him an Alaska license during the active revocation period. (Id. at 1043). The Court found that Alaska Statute AS 28.15.031(b)(1), which prohibits licensing any person whose driving privileges are suspended or revoked in Alaska or any other state, does not conflict with the Interstate Driver License Compact. (Id. at 1045). Additionally, the Court ruled that other related Alaska statutes regarding license applications and record sharing comply with the Compact and do not override it. (Id. at 1046). The Court reasoned that New York’s revocation of Rivera’s license did not improperly cede Alaska’s authority, as the Alaska DMV applied its own laws. (Id. at 1049). As a result, the judgment affirming the DMV’s denial of Rivera’s application was upheld. (Id. at 1051).
