State of Alaska, Department of Corrections v. Trevor Stefano

Summary

The court held that a prisoner serving a sentence on electronic monitoring has a constitutionally protected liberty interest in remaining outside prison, although electronic monitoring is not a formal rehabilitative program and its termination does not implicate a separate constitutional right to rehabilitation. The court nevertheless held that the superior court lacked appellate jurisdiction because DOC’s termination decision was not produced through an adjudicative process creating an adequate record for appellate review. The court vacated the portion of the superior court’s decision addressing termination and remanded for Stefano to convert his appeal into an original civil action.