Amerigold Holdings LLC v. Douglas Baker and Silverbow Mining LLC

Summary

The Alaska Supreme Court vacated the lower court’s dismissal of Amerigold’s laches defense and remanded for further findings on unreasonable delay and prejudice to a non‑party, while affirming the lower court’s admission of evidence about other alleged paper‑staking under Rule 404(b). The Court held that laches may apply to quiet‑title and declaratory‑judgment actions and that prejudice to a non‑party can satisfy the prejudice element of laches, but the lower court erred by not considering such prejudice. It also held that the testimony about prior paper‑staking was admissible to show absence of accident, not improper character evidence.