Patterson v. WalkerAnnotate this Case
Kevin Patterson has been incarcerated since 2013, having been convicted after a bench trial of seven counts of possession of child pornography. In May 2015 Patterson filed a 121-page civil complaint in superior court in Juneau. The complaint named as defendants the governor and his predecessor, the Alaska Legislature, a state senator, the then-current and two former attorneys general, an assistant attorney general, an attorney with the Office of Public Advocacy, and the State of Alaska. The complaint alleged that these state officials and entities had “directly harmed . . . Patterson in numerous ways and [had] violated his Constitutional Rights over and over.” It sought damages for Patterson’s incarceration, violence and emotional distress he allegedly suffered while in prison, and the alleged denial of medical care. The Alaska Supreme Court affirmed dismissal of Patterson’s complaint, holding a civil suit for damages allegedly caused by a criminal conviction or sentence may not be maintained if judgment for the plaintiff would necessarily imply the invalidity of the conviction or sentence, unless the conviction or sentence has first been set aside in the course of the criminal proceedings. The Court also rejected Patterson’s claim that the superior court demonstrated an unfair bias against him.