Darren M. v. Destiny D

Summary

The Alaska Supreme Court affirmed the superior court's amendment of written custody findings to reflect that the mother committed a single act of domestic violence, as the original trial judge had orally found. Because the father's attorney drafted findings that silently deviated from the oral ruling, and the second judge approved the draft without knowing of the discrepancies, the court held the mismatch was a clerical error correctable at any time under Alaska Civil Rule 60(a). It further held, applying the law of the case doctrine sua sponte, that the father could not challenge the oral findings as clearly erroneous after failing to timely move to amend, seek reconsideration, or appeal.