Egner v. Talbot's, Inc.

Summary

The Alaska Supreme Court affirmed summary judgment dismissing Carol Egner’s claims concerning her alleged shareholder status in Talbot’s, Inc. The court held that she was on inquiry notice no later than 1986 that her shareholder status was disputed and that the applicable statutes of limitations barred her claims. The court also discussed the continuing-violations doctrine and the effect of events occurring in 1995.

Holdings

1. Summary judgment may resolve a statute-of-limitations defense when uncontroverted facts establish when the plaintiff reasonably should have begun an inquiry to protect her rights. The undisputed facts established that Egner was on inquiry notice no later than 1986.
2. A genuine dispute about whether a plaintiff was actually a shareholder does not create a genuine dispute about whether she knew enough to be placed on inquiry notice of a disputed shareholder status.
3. The 1995 events did not create timely claims or revive Egner's shareholder-related claims because the denial of her purported shareholder status was a permanent violation occurring no later than 1986.

Questions Presented

1. Whether summary judgment was proper on the statute-of-limitations issue when the superior court had found a factual dispute about whether Egner was actually a shareholder.
2. Whether the undisputed facts established that Egner was on inquiry notice no later than 1986 that her purported shareholder status was denied or disputed.
3. Whether the 1995 events could support a continuing-violations theory or independently timely claims despite the 1986 permanent denial of shareholder status.

Disposition

affirmed