equitable estoppel doctrine (Alaska) · Go Syfert
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equitable estoppel doctrine in Alaska

12 Alaska opinions name it 2 courts 1906–2022 1 in the last five years

The cases below were cited by Alaska courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Jamison v. Consolidated Utilities, Inc.green
alaska · 1978 · cited in 3 Alaska opinions naming this issue, 1981–2011
2 sentences

2011Utils., Inc., 576 P.2d 97, 102 (Alaska 1978))); Sowinski v. Walker, 198 P.3d 1134, 1147 (Alaska 2008) (explaining that the doctrine of equitable estoppel "bars a speaker from taking a position inconsistent with a prior statement when another person has reasonably and detrimentally relied on the earlier statement" and that the doctrine's purpose is to "protect parties' reasonable expectations").

2011Utils., Inc., 576 P.2d 97, 102 (Alaska 1978))); Sowinski v. Walker, 198 P.3d 1134, 1147 (Alaska 2008) (explaining that the doctrine of equitable estoppel "bars a speaker from taking a position inconsistent with a prior statement when another person has reasonably and detrimentally relied on the earlier statement" and that the doctrine's purpose is to "protect parties' reasonable expectations").

33
Municipality of Anchorage v. Schneidergreen
alaska · 1984 · cited in 2 Alaska opinions naming this issue, 1997–2018
2 sentences

2018As explained by our supreme court in Anchorage v. Schneider , 685 P.2d 94 (Alaska 1984) : The general elements of equitable estoppel are (1) assertion of a position by conduct or word, (2) reasonable reliance thereon, and (3) resulting prejudice.

1997Crum’s claim meets the third and fourth elements of the estoppel test because his reliance resulted in prejudice, and application of the equitable estoppel doctrine in this case “serves the interest of justice so as to limit public injury.” In discussing this final element, we observed in Municipality of Anchorage v. Schneider, 685 P.2d 94, 97 (Alaska 1984), that even where reliance has been foreseeable, reasonable, and substantial, the interest of justice may not be served by the application of estoppel because the public interest would be significantly prejudiced.

12
Sowinski v. Walkergreen
alaska · 2008 · cited in 1 Alaska opinions naming this issue, 2011–2011
2 sentences

2011Utils., Inc., 576 P.2d 97, 102 (Alaska 1978))); Sowinski v. Walker, 198 P.3d 1134, 1147 (Alaska 2008) (explaining that the doctrine of equitable estoppel "bars a speaker from taking a position inconsistent with a prior statement when another person has reasonably and detrimentally relied on the earlier statement" and that the doctrine's purpose is to "protect parties' reasonable expectations").

2011Utils., Inc., 576 P.2d 97, 102 (Alaska 1978))); Sowinski v. Walker, 198 P.3d 1134, 1147 (Alaska 2008) (explaining that the doctrine of equitable estoppel "bars a speaker from taking a position inconsistent with a prior statement when another person has reasonably and detrimentally relied on the earlier statement" and that the doctrine's purpose is to "protect parties' reasonable expectations").

11
Anchorage v. Sandberggreen
alaska · 1993 · cited in 1 Alaska opinions naming this issue, 1995–1995
1 sentence

1995See City of Anchorage v. Sandberg, 861 P.2d 554, 558-59 (Alaska 1993) (defining a taking under principles of inverse condemnation); Homeward Bound v. Anchorage Sch.

11
Alaska Airlines, Inc. v. Lockheed Aircraft Corp.green
akd · 1977 · cited in 1 Alaska opinions naming this issue, 1983–1983
2 sentences

1983As we stated in Chiei v. Stern, 561 P.2d 1216, 1217 (Alaska 1977), “a party who fraudulently conceals from a plaintiff the existence of a cause of action may be estopped to plead the statute of limitation if the plaintiff’s delay in bringing suit was occasioned by reliance on the false or fraudulent representation.” See also Groseth v. Ness, 421 P.2d 624 (Alaska 1966); Alaska Airlines, Inc. v. Lockheed Aircraft Corp., 430 F.Supp. 134, 138 (D.Alaska 1977).

1983As we stated in Chiei v. Stern, 561 P.2d 1216, 1217 (Alaska 1977), "a party who fraudulently conceals from a plaintiff the existence of a cause of action may be estopped to plead the statute of limitation if the plaintiff's delay in bringing suit was occasioned by reliance on the false or fraudulent representation." See also Groseth v. Ness, 421 P.2d 624 (Alaska 1966); Alaska Airlines, Inc. v. Lockheed Aircraft Corp., 430 F. Supp. 134, 138 (D.Alaska 1977).

11
Chiei v. Sterngreen
alaska · 1977 · cited in 1 Alaska opinions naming this issue, 1983–1983
2 sentences

1983As we stated in Chiei v. Stern, 561 P.2d 1216, 1217 (Alaska 1977), “a party who fraudulently conceals from a plaintiff the existence of a cause of action may be estopped to plead the statute of limitation if the plaintiff’s delay in bringing suit was occasioned by reliance on the false or fraudulent representation.” See also Groseth v. Ness, 421 P.2d 624 (Alaska 1966); Alaska Airlines, Inc. v. Lockheed Aircraft Corp., 430 F.Supp. 134, 138 (D.Alaska 1977).

1983As we stated in Chiei v. Stern, 561 P.2d 1216, 1217 (Alaska 1977), "a party who fraudulently conceals from a plaintiff the existence of a cause of action may be estopped to plead the statute of limitation if the plaintiff's delay in bringing suit was occasioned by reliance on the false or fraudulent representation." See also Groseth v. Ness, 421 P.2d 624 (Alaska 1966); Alaska Airlines, Inc. v. Lockheed Aircraft Corp., 430 F. Supp. 134, 138 (D.Alaska 1977).

11
Automobile Club of Mich. v. Commissionergreen
scotus · 1957 · cited in 1 Alaska opinions naming this issue, 1982–1982
2 sentences

1982After noting that “[t]he doctrine of equitable estoppel is not a bar to the correction by the Commissioner of a mistake of law,” id. at 183 , 77 S.Ct. at 709 , 1 L.Ed.2d at 750 (footnote omitted), the Court held that the Commissioner had not abused his discretion in applying the revocation retroactively.

1982After noting that “[t]he doctrine of equitable estoppel is not a bar to the correction by the Commissioner of a mistake of law,” id. at 183 , 77 S.Ct. at 709 , 1 L.Ed.2d at 750 (footnote omitted), the Court held that the Commissioner had not abused his discretion in applying the revocation retroactively.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Alaska. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Groseth v. Ness green
alaska · 1966
2 sentences

1988We said in Russell that “[establishment of estoppel generally requires the party seeking to assert it to show ‘that the other party made some misrepresentation, or false statement, or acted fraudulently, and that he reasonably relied on such acts or representations ... and due to such reliance did not institute suit timely.’ ” *293 Russell, 743 P.2d at 376 (quoting Groseth v. Ness, 421 P.2d 624 , 632 n. 23 (Alaska 1966)).

1983As we stated in Chiei v. Stern, 561 P.2d 1216, 1217 (Alaska 1977), “a party who fraudulently conceals from a plaintiff the existence of a cause of action may be estopped to plead the statute of limitation if the plaintiff’s delay in bringing suit was occasioned by reliance on the false or fraudulent representation.” See also Groseth v. Ness, 421 P.2d 624 (Alaska 1966); Alaska Airlines, Inc. v. Lockheed Aircraft Corp., 430 F.Supp. 134, 138 (D.Alaska 1977).

21983–1988
Webb v. State, Department of Revenue, Child Support Enforcement Division Ex Rel. Webb green
alaska · 2005
2 sentences

2022As discussed above, our precedent reflects relatively few cases presenting the concerns at 39 Id. at 199-200 . 40 Id. at 200 (citing AS 25.27.060(a), which establishes that the obligee must administer child support on behalf of the children). 41 Child Support Enforcement Program; Implementation of Section 9103 of Public Law 99-509 ; Prohibition of Retroactive Modification of Child Support Arrearages, 54 Fed.

2022As discussed above, our precedent reflects relatively few cases presenting the concerns at 39 Id. at 199-200 . 40 Id. at 200 (citing AS 25.27.060(a), which establishes that the obligee must administer child support on behalf of the children). 41 Child Support Enforcement Program; Implementation of Section 9103 of Public Law 99-509 ; Prohibition of Retroactive Modification of Child Support Arrearages, 54 Fed.

12022–2022
James v. State green
alaska · 1991
1 sentence

1993In James v. State, 815 P.2d 352 , 355 n. 9 (Alaska 1991), we commented upon the difference between the doctrines of promissory and equitable estoppel, stating: Both parties cite precedents discussing not only promissory estoppel but also the related doctrine of equitable estoppel.

11993–1993
Russell v. Municipality of Anchorage green
alaska · 1987
1 sentence

1988We said in Russell that “[establishment of estoppel generally requires the party seeking to assert it to show ‘that the other party made some misrepresentation, or false statement, or acted fraudulently, and that he reasonably relied on such acts or representations ... and due to such reliance did not institute suit timely.’ ” *293 Russell, 743 P.2d at 376 (quoting Groseth v. Ness, 421 P.2d 624 , 632 n. 23 (Alaska 1966)).

11988–1988
Lee v. Town of Mound Station neutral
· 1886
1 sentence

1906This court in Lee v. Town of Mound Station, 118 Ill. 304 , says (p. 317) : “We have held that where the public have long withheld the assertion of control over streets, and private parties have been, by the 'acts of those representing the public, induced to believe the streets abandoned by the public, and on the faith of that belief, and with the acquiescence of those representing the public, they have placed themselves, by making structures or improvements in the streets, in a situation where they must suffer great pecuniary loss if those representing the public be allowed afterwards to alleg

11906–1906

Where else courts name it

CA 338 (1920–2026) NY 334 (1878–2026) IL 183 (1885–2026) TX 170 (1876–2026) PA 92 (1939–2024) FL 82 (1956–2025) NJ 80 (1926–2026) AL 67 (1884–2026) NC 66 (1926–2023) WA 65 (1910–2024) CT 61 (1860–2021) TN 55 (1902–2024) ME 54 (1938–2023) MS 53 (1896–2026) MD 51 (1917–2026) OH 50 (1901–2026) NE 42 (1896–2023) MI 41 (1901–2025) WI 41 (1882–2024) LA 37 (1926–2025) RI 34 (1990–2022) MN 32 (1896–2024) IN 30 (1893–2026) MT 29 (1910–2022) NM 29 (1944–2025) CO 27 (1911–2025) MO 27 (1900–2023) ND 26 (1959–2025) UT 23 (1994–2025) OR 22 (1894–2025) GA 21 (1975–2025) VA 21 (1897–2024) ID 20 (1909–2024) VT 20 (1895–2026) KS 20 (1892–2022) HI 19 (1942–2021) AZ 19 (1900–2023) WY 18 (1891–2025) SD 17 (1942–2026) DC 17 (1975–2012) SC 17 (1903–2025) KY 16 (1923–2023) IA 16 (1911–2024) MA 15 (1900–2024) AR 14 (1922–2024) DE 14 (1966–2025) WV 13 (1918–2022) AK 12 (1906–2022) OK 9 (1924–2024) NV 9 (1980–2018) VI 2 (2017–2025) NH 2 (1992–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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