From Casetext: Smarter Legal Research

Municipality of Anchorage v. Brown

Court of Appeals of Alaska
Apr 9, 1981
626 P.2d 116 (Alaska Ct. App. 1981)

Opinion

No. 5645.

April 9, 1981.

Petition for review from the District Court, Third Judicial District, Beverly W. Cutler, J.

Allen M. Bailey, Municipal Prosecutor, Theodore D. Berns, Municipal Atty., Anchorage, for petitioner.

Rich Zahniser, Asst. Public Defender, Dana Fabe, Acting Public Defender, Anchorage, for respondent.

Before BRYNER, C.J., COATS and SINGLETON, JJ.


OPINION


On February 23, 1981, we granted this petition for review of an order of the district court dated November 12, 1980, dismissing a prosecution against respondent for driving while license suspended (DWLS). The district court held that the Alaska Department of Public Safety's failure to give timely notice to respondent under AS 28.20.050 that his driver's license would be suspended if he failed to show financial responsibility or contest liability for an accident in which he had been involved precluded subsequent suspension of his license.

We have concluded that the trial court erred and therefore reverse. We read AS 28.20.050 as directory, not mandatory, and we conclude that a failure to give notice within thirty days, as required by the statute, does not preclude a subsequent suspension pursuant to the statute. While there may be a due process right to notice and a hearing as to liability within a reasonable time after an accident, and while that right might be violated in some instances where undue delay results in actual prejudice to the recipient of the late notice, that issue should properly be raised and decided on a case by case basis at the administrative hearing stage, not in a prosecution for driving with a suspended license. The order of the district court dismissing this prosecution is therefore reversed, and this case remanded for trial.


Summaries of

Municipality of Anchorage v. Brown

Court of Appeals of Alaska
Apr 9, 1981
626 P.2d 116 (Alaska Ct. App. 1981)
Case details for

Municipality of Anchorage v. Brown

Case Details

Full title:MUNICIPALITY OF ANCHORAGE, PETITIONER, v. JAMES A. BROWN, RESPONDENT

Court:Court of Appeals of Alaska

Date published: Apr 9, 1981

Citations

626 P.2d 116 (Alaska Ct. App. 1981)

Citing Cases

Schnabel v. State

The Commissioner denied the request (subject to further application by Schnabel in the "event of an…

McClain v. State

Aside from the fact that this court lacks jurisdiction to decide the matter, we believe the decision is best…