Alaska Stat. » Chapter 34.20
Alaska Statutes

Alaska Stat. § 34.20.100 (2026)

Deficiency judgment prohibited

✓ current as of July 2026
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Sec. 34.20.100. Deficiency judgment prohibited.
When a sale is made by a trustee under a deed of trust, as authorized by AS 34.20.070 — 34.20.130, no other or further action or proceeding may be taken nor judgment entered against the maker or the surety or guarantor of the maker, on the obligation secured by the deed of trust for a deficiency.


Notes of Decisions
Cited in 16 cases, 1966–2020 · leading case: Alaska Tr., LLC v. Ambridge, 372 P.3d 207 (Alaska 2016).
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Alaska Tr., LLC v. Ambridge, 372 P.3d 207 (Alaska 2016). · cites it 4× “In construing the term “debt collector,” courts have recognized that “if the enforcement of a security interest was synonymous with debt collection,” then the definitional sentence referencing security interests “would be surplusage because any business with a principal purpose…”
Hull v. Alaska Fed. Sav. & Loan Ass'n, 658 P.2d 122 (Alaska 1983). · cites it 8× “At issue is whether this retention of security after a non-judicial foreclosure on the property was proper under the Alaska anti-deficiency statute (AS 34.20.100) and common law principles. We hold that the retention was proper and affirm the superior court.”
Fireman's Fund Mortg. Corp. v. Allstate Ins. Co., 838 P.2d 790 (Alaska 1992). · cites it 4× “6 Furthermore, Fireman’s Fund persuasively argues that Alaska’s antideficiency statute, AS 34.20.100, is fundamentally different than Louisiana’s statute in that it does not operate to extinguish the underlying debt but merely eliminates certain *794 types of remedies against…”
Moening v. Alaska Mut. Bank, 751 P.2d 5 (Alaska 1988). · cites it 4× “Alaska Statute 09.45.200 provides: During or after the pendency of an action for the recovery of a debt secured by a lien mentioned in AS 09.”
Suber v. Alaska State Bond Comm., 414 P.2d 546 (Alaska 1966). · cites it 2× “AS 34.20.100, 18 which deals with deeds of trust, prohibits a deficiency judgment only in the special instance where the trustee sells the property pursuant to the deed of trust without a court action on the obligation secured by the deed of trust.”
Fitch v. Buffalo Fed. Sav. & Loan Ass'n, 751 P.2d 1309 (Wyo. 1988). · cites it 2× “See Alaska Stat. § 34.20.100 (1985) (deeds of trust); Ariz.”
Bibi v. Elfrink, 408 P.3d 809 (Alaska 2017). “080(b), (f)(1); AS 34.20.100. 79 . Elfrink also argues that to demonstrate he received cash proceeds from the foreclosure sale, Bibi needed to show that there was net equity in the property at the time of the sale and that Bibi was entitled to it.”
Adams v. FedAlaska Fed. Credit Union, 757 P.2d 1040 (Alaska 1988). · cites it 2× “See AS 34.20.100. The cost of giving junior lienholders this right will inevitably be a significant reduction in the ability of borrowers to rely on the fair market value of their property as protection in the event of a default.”
Watega v. Watega, 143 P.3d 658 (Alaska 2006). “Since we conclude that the lack of a sufficient justification for the sale in this case precluded the court from ordering the sale, we do not address the way in which sales pending divorce would need to be structured in the future in order to be permissible.”
Kuretich v. Alaska Tr., LLC, 287 P.3d 87 (Alaska 2012). “AS 34.20.100. . Young v. Embley, 143 P.3d 936, 939 (Alaska 2006) (quoting Native Vil.”
First State Bank of Forsyth v. Chunkapura, 734 P.2d 1203 (Mont. 1987). “Alaska Stat. § 34.20.100 (1985). However the Alaska Supreme Court has held that the provision against deficiency judgment does not apply if judicial foreclosure is pursued.”
Hickel v. Halford, 872 P.2d 171 (Alaska 1994). “the phrase 'other action or further action or proceeding’ as used in AS 34.20.100 means a form of litigation or some type of in-court proceeding.”
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