Frost v. Spencer
Alaska Supreme Court
218 P.3d 678 (2009)

- Written by Douglas Halasz, JD
Facts
Cathy Frost (plaintiff) and John Spencer (defendant) were high-school friends. Thereafter, Frost and Spencer were occasionally romantically involved, though they never cohabitated. In approximately 1989, Frost and Spencer started a business together, apparently without executing a written partnership agreement. The business initially provided guided hunting expeditions and then expanded to also offer catered events. Frost and Spencer acquired a lodge to serve as a business location for housing clients before expeditions and for hosting the catered events. The lodge was titled in Spencer’s name because of Frost’s financial complications stemming from a prior business. Frost and Spencer also purchased another lodge from Frost’s parents. During the business, Frost handled all the marketing, food service, and public relations while Spencer performed the hands-on work associated with the expeditions, the properties, and the equipment. By 2003, the professional relationship had soured. Spencer subsequently sued Frost and requested that the trial court dissolve the parties’ partnership interests and divide their jointly acquired real and personal properties. The parties expressly agreed that the trial court should apply domestic-partnership law to resolve the dispute and presented evidence during trial regarding the purchase and use of the real property and equipment during the partnership. Nevertheless, the trial court determined post-trial that business-partnership law should be used to resolve the dispute. Although the trial court permitted the parties to submit written arguments before it rendered a decision, it denied Frost’s request for another evidentiary hearing. Frost appealed and argued that the trial court abused its discretion by applying a different body of substantive law than she anticipated without holding another evidentiary hearing because she would have presented and emphasized different evidence.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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