Sidney Hertz, Appellant v. State of Alaska, Department of Corrections, Appellee

Summary

The Alaska Supreme Court affirmed the denial of Sidney Hertz's request to reinstate gate-money payments under a prison-conditions consent decree. It held that the Alaska Prison Litigation Reform Act applies because Hertz sought prospective relief, and that he failed to establish a statutory or contractual property right requiring continued enforcement of the gate-money provision or to satisfy an applicable exception. The court also held that any failure to rule on Hertz's request for appointed counsel was harmless because he had no statutory, constitutional, or due-process entitlement to counsel.