Alaska Supreme Court

Loren J. Larson Jr. v. State of Alaska, Department of Corrections, Board of Parole

November 20, 2020476 P.3d 293

Summary

The Alaska Supreme Court affirmed summary judgment for the Board of Parole, holding that requiring signed general and medical information-release forms as part of a clemency application did not violate the applicant's limited procedural due process protections. The requirement was reasonable, supported the Board's statutory investigative duties, and did not prevent the applicant from seeking clemency. The court assumed without deciding that the unconstitutional conditions doctrine could apply to clemency, but concluded that the applicant's claim failed under any articulated test.