Watkinson v. State of Alaska
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In the Supreme Court of the State of Alaska, the case involved a self-represented prisoner who sued the Department of Corrections (DOC) for intentional and negligent infliction of emotional distress. The prisoner alleged that DOC held him in administrative segregation (solitary confinement) for 504 days and that corrections officers denied him any meaningful opportunity to appeal or be heard regarding his segregation. The prisoner contended that the corrections officers’ actions amounted to extreme and outrageous conduct that caused him severe emotional distress. The superior court granted summary judgment in favor of DOC, reasoning that DOC’s conduct was not extreme and outrageous and that the prisoner’s distress was not severe enough to give rise to liability.
On appeal, the Supreme Court of the State of Alaska concluded that the superior court abused its discretion in dismissing the prisoner's claim of intentional infliction of emotional distress. The Supreme Court reversed the superior court’s grant of summary judgment in DOC’s favor as to the prisoner’s intentional infliction of emotional distress claim. The Supreme Court also vacated the superior court’s order approving the attorney general’s certification that individual corrections officers acted within the scope of their employment, reversed the court’s denial of the prisoner’s request to compel certain discovery, and remanded for further proceedings consistent with this decision. However, the Supreme Court affirmed the superior court’s grant of summary judgment with respect to the prisoner’s negligent infliction of emotional distress claim.
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