Alyeska Pipeline Service Co. v. Anderson

Whitten Anderson and Ronald Thomas filed a mining claim for green slate building stone located in an area north of Fairbanks, Alaska. Nearly a decade later, Aleyska Pipeline Service Co. (Aleyska) built a pipeline-access road across the mining claim. Anderson and Thomas leased access to the road to Aleyska. An Alyeska subcontractor then removed slate for pipeline construction from the area of Anderson and Thomas’s mining claim. The crew foreman knew he was not allowed to take the stone, but he took it anyway. Anderson and Thomas sued Aleyska for conversion of the slate. During trial, Anderson and Thomas submitted evidence of the slate’s value for use in decorative building fronts. Aleyska argued without evidentiary support that the market for decorative building stone was limited and that it could take decades to market the quantity of stone at issue. Aleyska further argued that Anderson and Thomas at best could have sold about 200 tons of rock per year at about $80 per ton, grossing about $16,000 per year. The trial court instructed the jury as to both the harsh and mild forms of damages for trespass-conversion, explaining that the mild form should apply to a good-faith trespasser. The jury applied the harsh form of damages, finding that Alyeska did not act in good faith and awarding Anderson and Thomas $1,911,429.40 in compensatory damages based on the slate’s value as decorative building stone. Anderson and Thomas’s claims for prejudgment interest and punitive damages were denied. Aleyska moved for remittitur or for a new trial, arguing in part that the damage award was excessive and the jury instructions on damages were incorrect. The trial court denied Alyeska’s motion, and Aleyska appealed. Anderson and Thomas cross-appealed, arguing they were entitled to prejudgment interest and punitive damages.