Edna K. v. Jeb S.

Summary

The Alaska Supreme Court reversed the superior court’s improper application of collateral estoppel to bar domestic‑violence evidence in a child‑custody modification, vacated its finding that no substantial change of circumstances existed, and remanded for an evidentiary hearing on the domestic‑violence allegations. The Court held that the issue was not fully litigated and that domestic violence constitutes a per‑se change of circumstances under Alaska statutes.