Stefano v. State of Alaska, Department of Corrections
Annotate this CaseIn this case, the Supreme Court of the State of Alaska reversed the Superior Court's decision and held that the Department of Corrections' policy change regarding the definition of "firm release date" for prisoners was a regulation that required compliance with the rulemaking procedures of the Administrative Procedures Act (APA). The Department of Corrections had changed its interpretation of "firm release date" twice. Initially, a prisoner's release date on discretionary parole was not considered a "firm release date." In 2016, the Department changed this interpretation and considered a discretionary parole release date as a "firm release date." However, in 2019, the Department reverted to its initial interpretation. The plaintiff, Trevor Stefano, a prisoner, argued that this change in policy violated the APA because it amounted to revising a regulation without going through the APA’s rulemaking process. The Supreme Court agreed with Stefano, noting that the Department's actions were a changed interpretation of existing regulation that had to be adopted through rulemaking. Because the Department did not follow the rulemaking procedure, the Court reversed the Superior Court's decision and remanded the case for further proceedings.
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