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Rathke v. Corrections Corp. of America

Alaska Supreme Court
153 P.3d 303 (2007)


Facts

Rathke (plaintiff) is an inmate in a prison in Arizona pursuant to a contract (the Contract) between the State of Alaska and the Corrections Corporation of America, Inc. (C.C.A.) (defendant). The Cleary FSA is an enforceable agreement between Alaska and Alaska inmates (including those incarcerated in Arizona) under which legal duties are owed to the prisoners. Many of the Cleary FSA’s provisions are repeated verbatim in the Contract between the State of Alaska and C.C.A. Rathke brought an action against C.C.A. alleging violations of the provisions regarding discipline of inmates. A provision of the Cleary FSA that is almost identical to the provision in the Contract provides that a prisoner is presumed innocent until proven guilty based on evidence presented at a hearing. The Superior Court of Alaska ruled that Alaska inmates incarcerated in an Arizona prison, such as Rathke, could not bring an action for breach of contract against C.C.A under the theory that they were third-party beneficiaries of the Contract. Rathke appealed to the Alaska Supreme Court contending that he was a third-party beneficiary of the Contract on the ground that the Contract incorporated many provisions of the Cleary FSA.

Rule of Law

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Issue

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Holding and Reasoning (Carpeneti, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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