parens patriae claim (Alaska) · Go Syfert
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parens patriae claim in Alaska

5 Alaska opinions name it 1 courts 1976–2024 2 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 (13)

CaseFollowedCited
New York v. Peter & John's Pump House, Inc.green
nynd · 1996 · cited in 2 Alaska opinions naming this issue, 2006–2024
2 sentences

2024Co., 324 U.S. 439, 449-51 (1945)). 61 Id. (citing Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592, 600- 02 (1982)). 62 Id. (quoting Snapp, 458 U.S. at 601-02). -21- 7684 interests a [sovereign] protects when, acting as ‘no more than a nominal party,’ it seeks to protect the interests of private parties in court.”63 Quasi-sovereign interests, which may form the basis for parens patriae actions, are a sovereign’s interests in “the well-being of its populace.”64 A sovereign may not create a parens patriae claim by aggregating the claims of its citizens.65 Rather, the sovereign must “arti

2024Co., 324 U.S. 439, 449-51 (1945)). 61 Id. (citing Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 , 600- 02 (1982)). 62 Id. (quoting Snapp, 458 U.S. at 601-02 ). -21- 7684 interests a [sovereign] protects when, acting as ‘no more than a nominal party,’ it seeks to protect the interests of private parties in court.” 63 Quasi-sovereign interests, which may form the basis for parens patriae actions, are a sovereign’s interests in “the well-being of its populace.” 64 A sovereign may not create a parens patriae claim by aggregating the claims of its citizens.65 Rather, the sovereign must “

22
Keller v. Frenchgreen
alaska · 2009 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024Servs., Off. of Child.’s Servs., 518 P.3d 708, 717 (Alaska 2022) (quoting Keller v. French, 205 P.3d 299, 302 (Alaska 2009)). 58 R.J.M. v. State, 946 P.2d 855, 871 (Alaska 1997). 59 In Tuluksak Native Cmty. v. State, Dep’t of Health & Soc.

2024Servs., Off. of Child.’s Servs., 518 P.3d 708, 717 (Alaska 2022) (quoting Keller v. French, 205 P.3d 299, 302 (Alaska 2009)). 58 R.J.M. v. State, 946 P.2d 855, 871 (Alaska 1997). 59 In Tuluksak Native Cmty. v. State, Dep’t of Health & Soc.

11
Georgia v. Pennsylvania Railroadyellow
scotus · 1945 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024Co., 324 U.S. 439, 449-51 (1945)). 61 Id. (citing Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 , 600- 02 (1982)). 62 Id. (quoting Snapp, 458 U.S. at 601-02 ). -21- 7684 interests a [sovereign] protects when, acting as ‘no more than a nominal party,’ it seeks to protect the interests of private parties in court.” 63 Quasi-sovereign interests, which may form the basis for parens patriae actions, are a sovereign’s interests in “the well-being of its populace.” 64 A sovereign may not create a parens patriae claim by aggregating the claims of its citizens.65 Rather, the sovereign must “

2024Co., 324 U.S. 439, 449-51 (1945)). 61 Id. (citing Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 , 600- 02 (1982)). 62 Id. (quoting Snapp, 458 U.S. at 601-02 ). -21- 7684 interests a [sovereign] protects when, acting as ‘no more than a nominal party,’ it seeks to protect the interests of private parties in court.” 63 Quasi-sovereign interests, which may form the basis for parens patriae actions, are a sovereign’s interests in “the well-being of its populace.” 64 A sovereign may not create a parens patriae claim by aggregating the claims of its citizens.65 Rather, the sovereign must “

11
Alfred L. Snapp & Son, Inc. v. Puerto Rico Ex Rel. Barezgreen
scotus · 1982 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024Co., 324 U.S. 439, 449-51 (1945)). 61 Id. (citing Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 , 600- 02 (1982)). 62 Id. (quoting Snapp, 458 U.S. at 601-02 ). -21- 7684 interests a [sovereign] protects when, acting as ‘no more than a nominal party,’ it seeks to protect the interests of private parties in court.” 63 Quasi-sovereign interests, which may form the basis for parens patriae actions, are a sovereign’s interests in “the well-being of its populace.” 64 A sovereign may not create a parens patriae claim by aggregating the claims of its citizens.65 Rather, the sovereign must “

2024Co., 324 U.S. 439, 449-51 (1945)). 61 Id. (citing Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 , 600- 02 (1982)). 62 Id. (quoting Snapp, 458 U.S. at 601-02 ). -21- 7684 interests a [sovereign] protects when, acting as ‘no more than a nominal party,’ it seeks to protect the interests of private parties in court.” 63 Quasi-sovereign interests, which may form the basis for parens patriae actions, are a sovereign’s interests in “the well-being of its populace.” 64 A sovereign may not create a parens patriae claim by aggregating the claims of its citizens.65 Rather, the sovereign must “

11
Native Village of Chignik Lagoon v. State of Alaska, Department of Health & Social Services, Office of Children's Services, and Native Village of Walesgreen
alaska · 2022 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024Servs., Off. of Child.’s Servs., 518 P.3d 708, 717 (Alaska 2022) (quoting Keller v. French, 205 P.3d 299, 302 (Alaska 2009)). 58 R.J.M. v. State, 946 P.2d 855, 871 (Alaska 1997). 59 In Tuluksak Native Cmty. v. State, Dep’t of Health & Soc.

2024Servs., Off. of Child.’s Servs., 518 P.3d 708, 717 (Alaska 2022) (quoting Keller v. French, 205 P.3d 299, 302 (Alaska 2009)). 58 R.J.M. v. State, 946 P.2d 855, 871 (Alaska 1997). 59 In Tuluksak Native Cmty. v. State, Dep’t of Health & Soc.

11
R.J.M. v. Stategreen
alaska · 1997 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024Servs., Off. of Child.’s Servs., 518 P.3d 708, 717 (Alaska 2022) (quoting Keller v. French, 205 P.3d 299, 302 (Alaska 2009)). 58 R.J.M. v. State, 946 P.2d 855, 871 (Alaska 1997). 59 In Tuluksak Native Cmty. v. State, Dep’t of Health & Soc.

2024Servs., Off. of Child.’s Servs., 518 P.3d 708, 717 (Alaska 2022) (quoting Keller v. French, 205 P.3d 299, 302 (Alaska 2009)). 58 R.J.M. v. State, 946 P.2d 855, 871 (Alaska 1997). 59 In Tuluksak Native Cmty. v. State, Dep’t of Health & Soc.

11
Henson v. Stategreen
alaska · 1978 · cited in 1 Alaska opinions naming this issue, 2021–2021
1 sentence

2021Agency v. Superior Court, Third Judicial Dist., 534 P.2d 947, 949 (Alaska 1975) (“Traditionally, the states have been legitimately concerned with the area of family law, and, under the doctrine of parens patriae, in particular, in the promotion of the welfare of children dwelling within their boundaries.” (internal citations omitted)). 44 Henson v. State, 576 P.2d 1352, 1354 (Alaska 1978) (quoting P.H. v. State, 504 P.2d 837, 841 (Alaska 1972), superseded by statute, ch. 63, §§ 13, 15, SLA 1977, as recognized in In re F.S., 586 P.2d 607, 610 (Alaska 1978)). 45 AS 47.12.010(a). 46 Titus v. Stat

11
In Re FSgreen
alaska · 1978 · cited in 1 Alaska opinions naming this issue, 2021–2021
1 sentence

2021Agency v. Superior Court, Third Judicial Dist., 534 P.2d 947, 949 (Alaska 1975) (“Traditionally, the states have been legitimately concerned with the area of family law, and, under the doctrine of parens patriae, in particular, in the promotion of the welfare of children dwelling within their boundaries.” (internal citations omitted)). 44 Henson v. State, 576 P.2d 1352, 1354 (Alaska 1978) (quoting P.H. v. State, 504 P.2d 837, 841 (Alaska 1972), superseded by statute, ch. 63, §§ 13, 15, SLA 1977, as recognized in In re F.S., 586 P.2d 607, 610 (Alaska 1978)). 45 AS 47.12.010(a). 46 Titus v. Stat

11
Watson v. Stategreen
alaskactapp · 2017 · cited in 1 Alaska opinions naming this issue, 2021–2021
2 sentences

2021For example, a person convicted 58 (...continued) have been legitimately concerned with the area of family law, and, under the doctrine of parens patriae, in particular, in the promotion of the welfare of children dwelling within their boundaries.” (footnote omitted)). 59 AS 47.12.010(a). 60 Watson v. State, 400 P.3d 121, 123 (Alaska App. 2017) (“The legislature could validly decide that minors should not face [the consequences of a felony conviction] for their actions, even when the felony arises from the act of driving.”). 61 Id. (citing AS 12.55.125). -15- 7533 of a felony may be barred fro

2021For example, a person convicted 58 (...continued) have been legitimately concerned with the area of family law, and, under the doctrine of parens patriae, in particular, in the promotion of the welfare of children dwelling within their boundaries.” (footnote omitted)). 59 AS 47.12.010(a). 60 Watson v. State, 400 P.3d 121, 123 (Alaska App. 2017) (“The legislature could validly decide that minors should not face [the consequences of a felony conviction] for their actions, even when the felony arises from the act of driving.”). 61 Id. (citing AS 12.55.125). -15- 7533 of a felony may be barred fro

11
Titus v. State, Dept. of Administration, Division of Motor Vehiclesgreen
alaska · 2013 · cited in 1 Alaska opinions naming this issue, 2021–2021
1 sentence

2021Agency v. Superior Court, Third Judicial Dist., 534 P.2d 947, 949 (Alaska 1975) (“Traditionally, the states have been legitimately concerned with the area of family law, and, under the doctrine of parens patriae, in particular, in the promotion of the welfare of children dwelling within their boundaries.” (internal citations omitted)). 44 Henson v. State, 576 P.2d 1352, 1354 (Alaska 1978) (quoting P.H. v. State, 504 P.2d 837, 841 (Alaska 1972), superseded by statute, ch. 63, §§ 13, 15, SLA 1977, as recognized in In re F.S., 586 P.2d 607, 610 (Alaska 1978)). 45 AS 47.12.010(a). 46 Titus v. Stat

11
Public Defender Agency v. Superior Court, Third Judicial Districtgreen
alaska · 1975 · cited in 1 Alaska opinions naming this issue, 2021–2021
1 sentence

2021Agency v. Superior Court, Third Judicial Dist., 534 P.2d 947, 949 (Alaska 1975) (“Traditionally, the states have been legitimately concerned with the area of family law, and, under the doctrine of parens patriae, in particular, in the promotion of the welfare of children dwelling within their boundaries.” (internal citations omitted)). 44 Henson v. State, 576 P.2d 1352, 1354 (Alaska 1978) (quoting P.H. v. State, 504 P.2d 837, 841 (Alaska 1972), superseded by statute, ch. 63, §§ 13, 15, SLA 1977, as recognized in In re F.S., 586 P.2d 607, 610 (Alaska 1978)). 45 AS 47.12.010(a). 46 Titus v. Stat

11
P. H. v. Stategreen
alaska · 1972 · cited in 1 Alaska opinions naming this issue, 2021–2021
1 sentence

2021Agency v. Superior Court, Third Judicial Dist., 534 P.2d 947, 949 (Alaska 1975) (“Traditionally, the states have been legitimately concerned with the area of family law, and, under the doctrine of parens patriae, in particular, in the promotion of the welfare of children dwelling within their boundaries.” (internal citations omitted)). 44 Henson v. State, 576 P.2d 1352, 1354 (Alaska 1978) (quoting P.H. v. State, 504 P.2d 837, 841 (Alaska 1972), superseded by statute, ch. 63, §§ 13, 15, SLA 1977, as recognized in In re F.S., 586 P.2d 607, 610 (Alaska 1978)). 45 AS 47.12.010(a). 46 Titus v. Stat

11
U. S. Ex Rel. Lombardino v. Heydgreen
laed · 1970 · cited in 1 Alaska opinions naming this issue, 1976–1976
2 sentences

1976Lombardino v. Heyd, 318 F.Supp. 648, 651 (E.D.La.1970), aff'd per curiam, 438 F.2d 1027 (5th Cir. 1971). .In Gault , the Supreme Court was highly critical of the constitutional and theoretical bases of juvenile justice administration, particularly with respect to the traditional reliance on the doctrine of parens patriae.

1976Lombardino v. Heyd, 318 F. Supp. 648, 651 (E.D.La. 1970), aff'd per curiam, 438 F.2d 1027 (5th Cir.1971). [6] In Gault , the Supreme Court was highly critical of the constitutional and theoretical bases of juvenile justice administration, particularly with respect to the traditional reliance on the doctrine of parens patriae.

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Prince George's County v. Levigreen
mdd · 1977 · cited in 1 Alaska opinions naming this issue, 2006–2006
1 sentence

2006But see Prince George's County v. Levi, 79 F.R.D. 1, 4 (D.C.Md.1977) (concluding that a county lacked standing to bring a parens patriae claim to *400 protect the rights of African American citizens since there was "no indication why those blacks [were] helpless to challenge denial of their rights or how the [county] is affected by that denial in a way that is separate and distinct”). 48 .

11

Also cited on this issue (3)

CaseCitedYears
Rust v. State green
alaska · 1978
1 sentence

2006We noted in Rust that some courts have reasoned from the parens patriae principle to find that mentally ill persons, once committed, have a "right to treatment.” Id. at 140 .

12006–2006
In Re GAULT red
scotus · 1967
2 sentences

1976It noted: “The Latin phrase proved to be of great help to those who sought to rationalize the exclusion of juveniles from the constitutional scheme; but its meaning is murky and its historic creditials are of dubious relevance.” 387 U.S. at 16 , 87 S.Ct. at 1437 .

1976It noted: “The Latin phrase proved to be of great help to those who sought to rationalize the exclusion of juveniles from the constitutional scheme; but its meaning is murky and its historic creditials are of dubious relevance.” 387 U.S. at 16 , 87 S.Ct. at 1437 .

11976–1976
Jessie S. Lombardino v. Louis A. Heyd, Jr., Criminal Sheriff neutral
ca5 · 1971
2 sentences

1976Lombardino v. Heyd, 318 F.Supp. 648, 651 (E.D.La.1970), aff'd per curiam, 438 F.2d 1027 (5th Cir. 1971). .In Gault , the Supreme Court was highly critical of the constitutional and theoretical bases of juvenile justice administration, particularly with respect to the traditional reliance on the doctrine of parens patriae.

1976Lombardino v. Heyd, 318 F. Supp. 648, 651 (E.D.La. 1970), aff'd per curiam, 438 F.2d 1027 (5th Cir.1971). [6] In Gault , the Supreme Court was highly critical of the constitutional and theoretical bases of juvenile justice administration, particularly with respect to the traditional reliance on the doctrine of parens patriae.

11976–1976

Where else courts name it

NJ 34 (1953–2025) IL 26 (1978–2024) CA 23 (1964–2025) PA 16 (1964–2021) NY 16 (1968–2025) MD 13 (1984–2021) OH 13 (1988–2026) IN 10 (1979–2023) TX 9 (1946–2024) CO 8 (1970–2025) FL 8 (1977–2015) MT 7 (1962–2012) OK 7 (1963–2012) MN 7 (1987–2018) KS 7 (1977–2004) VT 6 (1983–2024) NE 6 (1968–2020) WV 6 (1963–2024) AK 5 (1976–2024) MA 4 (1979–2014) WA 4 (2014–2015) SC 4 (1989–2019) IA 4 (1985–2020) AZ 4 (1965–2022) TN 3 (1998–2014) LA 3 (1971–2008) NC 3 (1985–2025) MO 2 (1950–1988) VI 2 (1977–2014) MS 2 (1969–1982) VA 2 (1995–2003) DC 2 (1985–2018) MI 2 (1993–2008) NM 2 (1954–1990) WI 2 (1980–2006) CT 2 (1992–2000) GA 2 (1982–1995) AL 2 (1937–2008)

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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