Clarifying and reaffirming the state’s summary-judgment standard, the Alaska Supreme Court has reversed a lower court’s dismissal of alleged malfunctioning seat-belt claims filed against a car dealership. Christensen v. Alaska Sales & Serv. Inc., No. S-14963 (Alaska, order entered October 10, 2014). The plaintiff purchased a new Buick in 2004, then hit two moose while driving it in 2008. Later, an MRI spectroscopy revealed evidence of an injury that she and her co-plaintiff assert was the result of her hitting her head on something inside the car due to a defective seat belt that did not lock when pulled abruptly. They sued Alaska Sales & Service for her ongoing speech, short-term memory and mobility problems, and the district court granted summary judgment for the dealership, concluding that “no reasonable jury could find that the plaintiffs have proven that the seat belt . . . was defective.”
The supreme court disagreed with the lower court’s ruling, finding that genuine issues of material fact exist based on the evidence presented despite that the seat belts have since been replaced and the plaintiffs were unable to provide the previous belts as evidence. The court discussed at some length the development of the state’s summary-judgment standard and its refusal to embrace a change the U.S. Supreme Court adopted when applying the federal summary-judgment standard in 1986, requiring the federal courts to incorporate “the substantive evidentiary burdens applicable at trial into the summary judgment determination.” According to the court, the state standard is “lenient” and “does not allow trial courts, on the limited evidence presented at the summary judgment stage, to make trial-like credibility determinations, conduct trial-like evidence weighing, or decide whether a non-moving party has proved its case.”
Thus, the state’s summary-judgment rule requires only “a showing that a genuine issue of material fact exists to be litigated, and not a showing that a party will ultimately prevail” during trial. Here, because the plaintiffs presented evidence that “goes well beyond assumption and speculation, is not too incredible to be believed, and relates directly to the material issues in the case” and taking all reasonable inferences from the evidence in their favor, the court reversed the summary-judgment ruling and remanded the case for further proceedings.