Nicholas A. Gefre and Charles T. Beck

Summary

The Alaska Supreme Court affirmed dismissal of most claims as time-barred but reversed dismissal of the spoliation claim against BPK and limited legal-malpractice claims alleging failure to warn that claims against Steffen would expire. The court held that the applicable limitations periods, discovery-rule analysis, and equitable-estoppel inquiry barred the remaining claims, and that the superior court properly resolved the limitations issues in an evidentiary hearing. It also upheld an implied waiver of attorney-client privilege and clarified that certain litigation expenses may be recoverable as damages in a successful malpractice claim.