Koyukuk River Tribal Task Force on Moose Management v. Rue

Summary

The Alaska Supreme Court reviewed an award of partial costs and attorney's fees against the Koyukuk River Tribal Task Force on Moose Management after dismissal of its challenge to state moose-management actions. The court held that the Task Force might qualify as a public interest litigant and remanded for factual findings concerning its identity, membership, purpose, and eligibility. The court vacated the award of costs and attorney's fees pending that determination.

Holdings

1. A party must satisfy all four public interest litigant criteria, and the record was insufficient to determine whether the Task Force met those criteria because its identity, membership, purpose, and good-faith basis were not substantiated by evidence.
2. Civil Rules 79 and 82 applied because the Task Force brought a regular civil action rather than an administrative appeal, but the fee and cost award had to be vacated pending determination of the Task Force's public interest litigant status.

Questions Presented

1. Whether the superior court abused its discretion by awarding costs and attorney's fees without adequately determining whether the Task Force qualified as a public interest litigant.
2. Whether Alaska Civil Rules 79 and 82 applied to the action.

Disposition

vacated