Irvine v. McDougall
In Irvine v. McDougall, 4 Alaska 702, 704 (D. Alaska 1913) the court held that a lien claimant who wrote the words "subscribed and sworn to before me" at the end of his lien claim was valid verification under the statutory requirements.
The court stated that it would be better to have verification in the form of an affidavit, but because the statute did not prescribe the form for verification, the court was not inclined to say that the lien claim was invalid. Id. The lien law was designed to simplify proceedings and the court said this form of verification may be what the legislature intended. Id. Thus, the court ruled the lien claim verified. Id.