Schiel v. Union Oil Company of California

Schiel v. Union Oil Co. of Cal., 219 P.3d 1025 (Alaska 2009) · Supreme Court of Alaska · November 20, 2009 · No. S-13058

Summary

The Supreme Court of Alaska held that 2004 amendments to Alaska's workers' compensation statutes did not violate the plaintiff's rights to equal protection or due process under the Alaska Constitution. The amendments extended workers' compensation liability and related tort immunity to project owners and contractors. The court concluded that the provisions were rationally and fairly related to legitimate objectives, including expanding coverage, preventing double payment, and limiting tort liability.

Holdings

  1. The 2004 amendments to AS 23.30.045(a) and AS 23.30.055 do not violate Schiel's right to equal protection under the Alaska Constitution.
  2. The 2004 amendments do not violate Schiel's procedural due process right of access to the courts because the workers' compensation system provides a substantial and efficient alternative remedy.
  3. AS 23.30.055 does not violate Schiel's substantive due process rights.

Questions Presented

  1. Whether the 2004 amendments to Alaska Statutes 23.30.045(a) and 23.30.055 violate the Equal Protection Clause of the Alaska Constitution.
  2. Whether the 2004 amendments to Alaska Statutes 23.30.045(a) and 23.30.055 violate procedural due process under the Alaska Constitution by restricting access to tort remedies.
  3. Whether Alaska Statute 23.30.055, as applied to Schiel, violates substantive due process under the Alaska Constitution.

Disposition

other

Cases Cited (35)

  • Kallstrom v. United States, 43 P.3d 162, 164-65 (Alaska 2002)(followed)
  • Edenshaw v. Safeway, Inc., 186 P.3d 568, 569 (Alaska 2008)(followed)
  • Berg v. Popham, 113 P.3d 604, 607 (Alaska 2005)(followed)
  • M.A. v. United States, 951 P.2d 851, 853 (Alaska 1998)(followed)
  • Glover v. State, Dep't of Transp., Alaska Marine Highway Sys., 175 P.3d 1240, 1256-58 (Alaska 2008)(followed)
  • Matanuska-Susitna Borough Sch. Dist. v. State, 931 P.2d 391, 397 (Alaska 1997)(followed)
  • C.J. v. State, Dep't of Corr., 151 P.3d 373, 378-81 (Alaska 2006)(followed)
  • Wilkerson v. State, Dep't of Health & Soc. Servs., Div. of Family & Youth Servs., 993 P.2d 1018, 1022-24 (Alaska 1999)(followed and distinguished)
  • Alaska Pac. Assurance Co. v. Brown, 687 P.2d 264, 269 (Alaska 1984)(followed)
  • State, Dep'ts of Transp. & Labor v. Enserch Alaska Constr., Inc., 787 P.2d 624, 631-33 (Alaska 1989)(distinguished)

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