Carlson v. State (1979)
In Carlson v. State, 598 P.2d 969, 970 (Alaska 1979), plaintiff was mauled by a bear. Potential liability arose not from a responsibility to control the bear, but from the accumulation of garbage that attracted the bear to the highway turnout where it encountered and mauled the plaintiff. Id. at 970-71.
The decision to not remove litter from the turnout was an operational decision for which the State was not immune. Id. at 972.
Because the alleged negligence was the creation of a dangerous situation by not removing litter, as opposed to its inherent possession and control of wild animals, the doctrine of ferae naturae did not apply. Id. at 973.