Personal Injury Complaint - Slip and Fall - Alaska

COMPLAINT FOR PERSONAL INJURY — SLIP AND FALL

Before filing: Complete the court's case description form required by Civil Rule 3(a). AS 09.10.070(a) generally requires a personal injury action within two years after accrual, subject to other law. For a damages claim within AS 22.15.030(a)(1)'s $100,000 per-defendant limit, use District Court unless a Supreme Court rule permits Superior Court filing. Confirm the premises, defendant's control, court, venue, and any governmental-defendant requirements from the actual facts. A jury demand must be a separate signed writing under Civil Rule 38(b).

IN THE [SUPERIOR / DISTRICT] COURT FOR THE STATE OF ALASKA

[____] JUDICIAL DISTRICT AT [LOCATION]

Case No.: [________]

Plaintiff alleges:

1. Parties, jurisdiction, and venue

1. Plaintiff [NAME] resides at [ADDRESS]. Defendant [NAME] is [INDIVIDUAL / ENTITY] with [ADDRESS]. Defendant [OWNED / OCCUPIED / MANAGED / CONTROLLED] the premises at [ADDRESS] when the incident occurred, as shown by [FACTS].
2. The amount claimed against [DEFENDANT] is [AMOUNT], exclusive of costs, interest, and attorney fees. [STATE THE FACTUAL BASIS FOR THIS COURT'S JURISDICTION UNDER AS 22.10.020 OR AS 22.15.030(a)(1), INCLUDING ANY SUPERIOR COURT EXCEPTION RELIED UPON].
3. Personal jurisdiction exists under AS 09.05.015(a)([1 / 3 / OTHER VERIFIED GROUND]) because [STATE DOMICILE, IN-STATE SERVICE, OR THE DEFENDANT'S IN-STATE ACT OR OMISSION CAUSING INJURY].
4. Venue is proper in this judicial district under Civil Rule 3(c) because [IDENTIFY WHERE THE CLAIM AROSE OR WHERE DEFENDANT MAY BE PERSONALLY SERVED, AND THE RULE'S APPLICABLE CONDITION].

2. Incident and injury

5. On [__/__/____], Plaintiff was at [SPECIFIC PREMISES LOCATION] for [PURPOSE AND ENTRY FACTS]. The premises were [DESCRIBE IMPROVED OR UNIMPROVED STATUS AND RELEVANT CONDITIONS].
6. Plaintiff [DESCRIBE MOVEMENT AND OBSERVATIONS] when [DESCRIBE FALL]. The alleged hazard was [LOCATION, DIMENSIONS, MATERIAL, LIGHTING, WEATHER, AND OTHER FACTS].
7. Defendant created or learned of the hazard through [FACTS], or the hazard existed long enough that [DESCRIBE NOTICE FACTS]. Defendant [IDENTIFY INSPECTION, REPAIR, REMOVAL, OR WARNING THAT WAS REASONABLY POSSIBLE AND OMITTED].
8. Plaintiff received [TREATMENT AND DATES], incurred [MEDICAL COSTS AND OTHER ECONOMIC LOSSES], and experienced [DESCRIBE NONECONOMIC HARM SUPPORTED BY THE RECORD].

3. Count I — negligence

9. Plaintiff incorporates paragraphs 1–8. Given Defendant's control of the premises and the circumstances described above, Plaintiff alleges Defendant owed reasonable care to prevent foreseeable harm from [SPECIFIC CONDITION].
10. Defendant breached that duty by [SPECIFIC ACT OR OMISSION]. That breach was a substantial factor in causing Plaintiff's fall and identified injuries. [STATE FACTS ADDRESSING CAUSATION, NOTICE, AND ANY OTHER CAUSES].

4. Count II — violation of a specific safety law (use only if supported)

11. [IDENTIFY AND QUOTE A SPECIFIC APPLICABLE BUILDING, MAINTENANCE, OR OTHER SAFETY LAW AND THE FACTS SHOWING ITS VIOLATION. OMIT THIS COUNT IF NONE APPLIES.] Plaintiff alleges that Defendant's [CONDUCT] violated that provision and caused [IDENTIFIED HARM].
12. Plaintiff requests a negligence-per-se determination only if the Court finds that the provision establishes a sufficiently specific standard of care for this claim, protects Plaintiff's class against this type of harm, and any claimed excuse does not defeat its application. See Alaska Civil Pattern Jury Instruction 3.04A. If the Court does not adopt the provision as the standard, Plaintiff proceeds on Count I and any other supported theory.

5. Damages and fault

13. Plaintiff seeks proven past and future medical expense, lost earnings or earning capacity, and other economic loss, itemized as follows: [CATEGORIES, AMOUNTS, SUPPORT].
14. Plaintiff seeks proven noneconomic loss of [DESCRIBE], subject to AS 09.17.010. The ordinary limit in subsection (b) is the greater of $400,000 or life expectancy in years multiplied by $8,000 for all claims from a single injury. If severe permanent physical impairment or severe disfigurement is proven, subsection (c) permits the greater of $1,000,000 or life expectancy in years multiplied by $25,000.
15. Plaintiff disputes any asserted fault attributable to Plaintiff. If fault is found, AS 09.17.060 reduces compensatory damages in proportion to Plaintiff's fault without barring recovery.

6. Prayer for relief

Plaintiff asks for judgment awarding:

1. Economic damages proved at trial;
2. Noneconomic damages within AS 09.17.010;
3. Prejudgment and postjudgment interest as allowed by AS 09.30.070, excluding future economic and future noneconomic damages from prejudgment interest under subsection (c);
4. Costs and attorney fees to the extent awarded under applicable law and Civil Rule 82; and
5. Further relief supported by the pleadings and evidence.

Dated: [__/__/____]

[________________________________]

[ATTORNEY NAME, ALASKA BAR NO.]

[ADDRESS / PHONE / EMAIL]

Attorney for Plaintiff

Service planning

Civil Rule 4 requires the summons and complaint to be served together. After service, record the actual date, recipient, method, and proof of service in the filing required by the applicable rule: [SERVICE FACTS].

Separate jury demand (optional companion)

IN THE [SUPERIOR / DISTRICT] COURT FOR THE STATE OF ALASKA

[____] JUDICIAL DISTRICT AT [LOCATION]

Case No.: [________]

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury on all issues triable of right by a jury under Alaska Civil Rule 38.

Dated: [__/__/____]

[________________________________]

[ATTORNEY NAME, ALASKA BAR NO.]

Sources and references

• Alaska Legislature: Title 9, AS 22.10.020, and AS 22.15.030 (accessed 2026-10-05).
• Alaska Civil Rules and Alaska Civil Pattern Jury Instructions (accessed 2026-10-05).

Disclaimer: This form is informational and is not legal advice. Have Alaska counsel review the facts and current law before filing.