Ramona Christensen and Jack Scott, Appellants v. Alaska Sales & Service, Inc., Appellee

Summary

The Alaska Supreme Court reversed summary judgment for a car dealership in a strict products liability suit arising from a 2008 moose collision that left the driver with bilateral frontal lobe brain damage. The court clarified and reaffirmed Alaska's summary judgment standard: a non-moving party need not prove its case, but must show specific admissible facts reasonably tending to dispute the movant's evidence, and courts may not weigh evidence or make credibility determinations at the summary judgment stage. Applying that standard, the court held that evidence of pre-accident and post-replacement seat belt lock-up failures, the absence of seat belt bruising, and symptom onset immediately after the collision created genuine issues of material fact on both defect and causation. The court also disavowed prior statements equating the summary judgment and directed verdict standards.