Larson v. State, Dept. of Corrections
Annotate this CaseLoren J. Larson, Jr. was incarcerated at the Spring Creek Correctional Center in Seward. Acting pro se, he filed two separate complaints alleging violations of his constitutional rights. In his first complaint, he alleged that he suffers from paruresis, a condition that makes it impossible for him to urinate in the presence of others, and the correctional facility had violated state and federal constitutional prohibitions against cruel and unusual punishment by failing to accommodate his condition with alternative urinalysis testing procedures. His second complaint alleged that the correctional facility's revised visitor application form for minors violates his state constitutional right to rehabilitation because it is more restrictive than the administrative regulation governing visitation rights. Both complaints were dismissed for failure to state a claim under Alaska Civil Rule 12(b)(6). The Supreme Court consolidated the two appeals to address an issue common to both: the procedure for properly evaluating a Rule 12(b)(6) motion to dismiss the complaint of a pro se prisoner alleging constitutional violations. The Court took the opportunity to emphasize that a complaint must be liberally construed and a motion to dismiss under Rule 12(b)(6) is viewed with disfavor and should rarely be granted. Because both of Larson's complaints alleged facts which, if proven, were sufficient to entitle him to some form of relief, and because the Court found no merit in the arguments that Larson lacked standing or was otherwise barred from bringing a direct cause of action for these alleged constitutional violations, the Court reversed the dismissal of both of Larson's complaints.
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