Alaska Statutes
Alaska Stat. § 45.50.537 (2026)
Attorney fees, costs, and damages
✓ current as of July 2026
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Sec. 45.50.537. Attorney fees, costs, and damages.
(a) In an action brought by a private person under AS 45.50.471 — 45.50.561, a prevailing plaintiff shall be awarded costs as provided by court rule and full reasonable attorney fees at the prevailing reasonable rate.
(b) Unless the action is found to be frivolous, in an action brought by a private person under AS 45.50.471 — 45.50.561, a prevailing defendant shall be awarded attorney fees and costs as provided by court rule. If the action is found to be frivolous, the attorney fees to be awarded to the defendant shall be full reasonable attorney fees at the prevailing reasonable rate.
(c) Notwithstanding the other provisions of this section, in an action brought by a private person under AS 45.50.471 — 45.50.561, if the plaintiff is not the prevailing party and if the court finds that the action was brought by the plaintiff to obtain a competitive business advantage, the court shall award a prevailing defendant costs as provided by court rule, full reasonable attorney fees at the prevailing reasonable rate, and any damages suffered by the prevailing defendant as a result of the plaintiff's allegations.
(d) In an action brought by the attorney general under AS 45.50.471 — 45.50.561, if the attorney general prevails, the state shall be awarded its actual attorney fees and costs, including costs of investigation, to the extent those fees and costs are reasonable.
(e) In this section, “frivolous” means
(1) not reasonably based on evidence or on existing law or a reasonable extension, modification, or reversal of existing law; or
(2) brought to harass the defendant or to cause unnecessary delay or needless expense.
(a) In an action brought by a private person under AS 45.50.471 — 45.50.561, a prevailing plaintiff shall be awarded costs as provided by court rule and full reasonable attorney fees at the prevailing reasonable rate.
(b) Unless the action is found to be frivolous, in an action brought by a private person under AS 45.50.471 — 45.50.561, a prevailing defendant shall be awarded attorney fees and costs as provided by court rule. If the action is found to be frivolous, the attorney fees to be awarded to the defendant shall be full reasonable attorney fees at the prevailing reasonable rate.
(c) Notwithstanding the other provisions of this section, in an action brought by a private person under AS 45.50.471 — 45.50.561, if the plaintiff is not the prevailing party and if the court finds that the action was brought by the plaintiff to obtain a competitive business advantage, the court shall award a prevailing defendant costs as provided by court rule, full reasonable attorney fees at the prevailing reasonable rate, and any damages suffered by the prevailing defendant as a result of the plaintiff's allegations.
(d) In an action brought by the attorney general under AS 45.50.471 — 45.50.561, if the attorney general prevails, the state shall be awarded its actual attorney fees and costs, including costs of investigation, to the extent those fees and costs are reasonable.
(e) In this section, “frivolous” means
(1) not reasonably based on evidence or on existing law or a reasonable extension, modification, or reversal of existing law; or
(2) brought to harass the defendant or to cause unnecessary delay or needless expense.
Notes of Decisions
Cited in 20
cases (7 in the last 5 years), 2001–2025 · leading case: Adkins v. Collens, 444 P.3d 187 (Alaska 2019).
Adkins v. Collens, 444 P.3d 187 (Alaska 2019). “It then determined attorney's fees for Collens's UTPA claim per AS 45.50.537(a), which states that a prevailing private plaintiff in an UTPA action "shall be awarded costs as provided by court rule and full reasonable attorney fees at the prevailing reasonable rate.”
Albrecht v. Alaska Tr., LLC, 286 P.3d 1059 (Alaska 2012). “The superior court awarded attorney's fees to Alaska Trustee as the prevailing party, enhancing those fees under AS 45.50.537(b) on the ground that Albrecht's claims were frivolous.”
Kenai Chrysler Ctr., Inc. v. Denison, 167 P.3d 1240 (Alaska 2007). “[71] AS 45.50.537(a) provides: "In an action brought by a private person under AS 45.”
State v. Native Vill. of Nunapitchuk, 156 P.3d 389 (Alaska 2007). “(c) This Act does not preclude the enactment of specific statutes authorizing awards of costs or fees in particular situations, such as in AS 45.50.537. * Sec. 2. AS 09.60.010 is amended by adding new subsections to read: (b) Except as otherwise provided by statute, a court in…”
Casciola v. F.S. Air Serv., Inc., 120 P.3d 1059 (Alaska 2005). “AS 45.50.537. 25 . Compare _ AS with _ AS 09.”
Deloycheet, Inc. v. Beach (In re Beach), 570 B.R. 300 (Bankr. D. Alaska 2017). “” 200 The provision for “full reasonable attorney’s fees” under AS 45.50.537(a) is distinguishable from an award of fees under Alaska Civil Rule 82.”
Asrc Energy Servs. Power v. Golden Valley Elec. Ass'n, 267 P.3d 1151 (Alaska 2011). “AS 45.50.537(a) provides: In an action brought by a private person under AS 45.”
Pepper v. Routh Crabtree, APC, 219 P.3d 1017 (Alaska 2009). “29, 2009) ("To find defendants immunized by the Noerr-Pennington doctrine would eviscerate the Fair Debt Collection Practices Act. Debt collectors should not be able to employ tactics forbidden by the FDCPA simply because they also happen to be lawyers, or because they are…”
Garrison v. Dixon, 19 P.3d 1229 (Alaska 2001). “531(¢g) with AS 45.50.537. Neither party argues that the new section .”
Borgen v. A & M Motors, Inc., 273 P.3d 575 (Alaska 2012). “AS 45.50.537(a) provides: In an action brought by a private person under AS 45.”
Compton v. Kittleson, 171 P.3d 172 (Alaska 2007). “While the settlement left his client satisfied, Kittleson noted, the contingent-fee share of the recovery yielded just $2,500 for a case in which Kittleson had invested roughly $16,000 worth of his time.”
Portfolio Recovery Assocs., LLC v. Jeannie Duvall, Jeannie Duvall v. Portfolio Recovery Assocs., LLC , Portfolio Recovery Assocs., LLC v. Allease Riddle, Portfolio Recovery Assocs., LLC v. Lorrena Terry, Allease Riddle v. Portfolio Recovery Assocs., LLC, Portfolio Recovery Assocs., LLC v. Lorrena Terry (Alaska 2025). “160 An award of full reasonable attorney’s fees, as well as statutory damages based solely on those same attorney’s fees, strikes us as a double recovery the legislature could not have intended.”
— Alaska Stat. § 45.50.537(a) — 11 cases
Adkins v. Collens, 444 P.3d 187 (Alaska 2019). “It then determined attorney's fees for Collens's UTPA claim per AS 45.50.537(a), which states that a prevailing private plaintiff in an UTPA action "shall be awarded costs as provided by court rule and full reasonable attorney fees at the prevailing reasonable rate.”
Kenai Chrysler Ctr., Inc. v. Denison, 167 P.3d 1240 (Alaska 2007). “[71] AS 45.50.537(a) provides: "In an action brought by a private person under AS 45.”
Deloycheet, Inc. v. Beach (In re Beach), 570 B.R. 300 (Bankr. D. Alaska 2017). “” 200 The provision for “full reasonable attorney’s fees” under AS 45.50.537(a) is distinguishable from an award of fees under Alaska Civil Rule 82.”
Asrc Energy Servs. Power v. Golden Valley Elec. Ass'n, 267 P.3d 1151 (Alaska 2011). “AS 45.50.537(a) provides: In an action brought by a private person under AS 45.”
Borgen v. A & M Motors, Inc., 273 P.3d 575 (Alaska 2012). “AS 45.50.537(a) provides: In an action brought by a private person under AS 45.”
— Alaska Stat. § 45.50.537(b) — 2 cases
Albrecht v. Alaska Tr., LLC, 286 P.3d 1059 (Alaska 2012). “The superior court awarded attorney's fees to Alaska Trustee as the prevailing party, enhancing those fees under AS 45.50.537(b) on the ground that Albrecht's claims were frivolous.”
Jeannie Duvall v. Portfolio Recovery Assocs., LLC (Alaska 2022).
— Alaska Stat. § 45.50.537(e) — 1 case
Albrecht v. Alaska Tr., LLC, 286 P.3d 1059 (Alaska 2012). “The superior court awarded attorney's fees to Alaska Trustee as the prevailing party, enhancing those fees under AS 45.50.537(b) on the ground that Albrecht's claims were frivolous.”
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