Friday, November 29, 2013

Alaska Northern Development, Inc. v. Alyeska Pipeline Service Co. case brief

Alaska Northern Development, Inc. v. Alyeska Pipeline Service Co. case brief summary
666 P.2d 33 (1983)

Appellant contractor appealed the decision of the Superior Court of the State of Alaska in favor of appellee pipeline in a dispute involving contract formation and interpretation.

The contractor initiated discussion with the pipeline regarding the purchase of surplus parts. The parties executed a letter of intent, subject to the final approval of the pipeline's owner committee. The committee rejected the proposed purchase, and the contractor filed a complaint alleging breach of contract.


  • The court held that the superior court correctly applied the parol evidence rule, Alaska Stat. § 45.02.202, to the letter of intent, and that no extrinsic evidence could be presented to a jury which limited the committee's right of approval. 
  • Such evidence would be inconsistent with the integrated term that unconditionally gave the committee the right to approval. 
  • Because the superior court refused to reform the contract, the contractor had no legal claim to present to a jury. 
  • Since the contractor did not point to any evidence that would give rise to an inference of actual malice or conduct sufficiently outrageous to be deemed equivalent to actual malice, and since the contractor did not produce direct evidence that it was the intended victim of a conspiracy theory, it was not error to grant summary judgment on the punitive damages issue.

The court affirmed the judgment of the superior court.

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