Department of Corrections v. Kraus

In Department of Corrections v. Kraus, 759 P.2d 539 (Alaska 1988) two prisoners were sanctioned by a prison disciplinary committee. After exhausting their remedies within the prison system, they filed an administrative appeal in the superior court. The State argued that the action of the Department of Corrections was not appealable and that the courts lacked jurisdiction to decide the appeal. The supreme court granted the State's petition for review on this issue. The supreme court held that the state courts had jurisdiction to review the Department of Corrections's action to determine whether the defendants had received fundamental due process. The supreme court specifically rejected the State's suggestion that any review of the Department of Corrections's decision should be conducted as a post-conviction relief action. The court stated that the proper procedural vehicle was an appeal of the administrative decision rather than an application for post-conviction relief.The Court held that the superior court had jurisdiction to review the Department's disciplinary decisions to determine whether the defendants had received fundamental due process. But the supreme court specifically rejected the State's suggestion that any review of the Department's decision should be conducted as a post-conviction relief action. The supreme court reasoned that the proper procedural vehicle was an appeal of the administrative decision rather than an application for post-conviction relief.