In City of Kotzebue v. Ipalook, 462 P.2d 75 (Alaska 1969) the Alaska Supreme Court evaluated whether a party could challenge a relative of a witness for cause under Alaska Civil Rule 47(c)(9), the rule for challenging jurors in civil cases, which was (and remains) substantially similar to Criminal Rule 24(c)(9). In Ipalook, the Supreme Court stated "that relationship to a witness does not fall within any of the enumerated grounds under Civil Rule 47(c) upon which a prospective juror can be challenged for cause."