Schultz v. Wells Fargo Bank, N.A.

Summary

The Alaska Supreme Court held that a trust advisory committee was the prevailing party in litigation seeking insurance-related information and documents from the trustee. Although the committee obtained only about half of its requested disclosures, it secured an order requiring production of the master insurance policy and other information relevant to the trustee's fiduciary duties. The court reversed the denial of attorney's fees under Alaska Civil Rule 82 and remanded for renewed consideration of the fee award.

Holdings

1. The Trust Advisory Committee was the prevailing party because it obtained substantial affirmative relief: a court order recognizing Wells Fargo's fiduciary obligation to provide information and directing Wells Fargo to produce the master insurance policy and approximately half of the requested information and documents.
2. The superior court abused its discretion by treating the case as a split result based primarily on the Committee's success on roughly half of its disclosure requests and by failing to recognize the Committee as prevailing on the main issue.

Questions Presented

1. Whether the superior court abused its discretion by determining that neither the Trust Advisory Committee nor Wells Fargo was the prevailing party for purposes of Alaska Civil Rule 82 attorney's fees.
2. Whether a party may be the prevailing party under Alaska Civil Rule 82 when it obtains substantial affirmative relief but not all of the relief requested.

Disposition

reversed_and_remanded