August 14, 2026 Case Summaries

The Enhance Law Enforcement Integrity Act does not allow a law enforcement agency to condition its mandatory obligation to produce “all unedited video and audio recordings . . . within twenty-one days” for “incidents in which there is a complaint of peace officer misconduct” on the payment of fees.

The OSPD isn’t a criminal justice agency within the meaning of the CCJRA.

The trial court correctly found that the officer had reasonable suspicion to seize R.W. after observing, at 2 a.m., two occupants bolt from the car, and R.W. start to drive away with the door still open, when he pulled up.

The district court has an independent duty to investigate juror bias that emerges during trial. The district court’s duty to investigate cannot itself be waived by the parties, and an adequate investigation by the court is a prerequisite to any knowing waiver of a juror bias claim by the defendant.

A search occurs when the government, including its dogs, trespasses onto private property for the purpose of gathering information. Here, Lara the drug dog committed a trespass by sticking her snout through the open car window. Since the sniff was calculated to detect the presence of drugs, this was a search under the 4th Amendment. However, suppression of the evidence was not necessary since the officers reasonably relied on prior precedent indicating this was not a search.

The district court did not err in granting habeas relief to Turner based on his claim of ineffective assistance of trial counsel for failing to adequately challenge the government’s presentation of cell site location information (CSLI) using a GeoTime video.

After a defendant waives his Miranda rights and submits to an interrogation, if the defendant makes an ambiguous request for counsel the officer is required to “stop and clarify” by, for example, “asking if the suspect wishes to obtain legal counsel.” This new “stop and clarify” law is not required under SCOTUS jurisprudence. Instead, the Court bases the decision on the Alaska Constitution Article I, Section 11 right to counsel and Article I, Section 9’s corollary to the Fifth Amendment.