State Court Complaint - Personal Injury - Alaska

COMPLAINT FOR PERSONAL INJURY — NEGLIGENCE

Before filing: Complete the case description form required by Alaska 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 money 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 jurisdiction and venue from the case 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]. [IDENTIFY EACH ADDITIONAL DEFENDANT AND ITS ROLE].
2. The amount claimed against each Defendant is [AMOUNT BY DEFENDANT], 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. Facts and injury

5. On [__/__/____] at [LOCATION], Plaintiff [DESCRIBE ACTIVITY AND RELATIONSHIP TO EACH DEFENDANT].
6. Defendant [NAME] [DESCRIBE SPECIFIC ACTS OR OMISSIONS, DATES, AND CIRCUMSTANCES]. Defendant [ADDITIONAL NAME] [DESCRIBE SEPARATE CONDUCT, IF ANY].
7. The incident occurred as follows: [SEQUENCE, SUPPORTING EVIDENCE, AND ANY OTHER CAUSES]. Plaintiff suffered [IDENTIFY ACTUAL INJURIES].
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. Each Defendant owed Plaintiff reasonable care under [IDENTIFY THE RELATIONSHIP, ACTIVITY, AND FACTS SUPPORTING THE ALLEGED DUTY].
10. Defendant [NAME] breached that duty by [SPECIFIC CONDUCT]. The breach was a substantial factor in causing [IDENTIFIED INJURY AND LOSS]. [SEPARATELY ALLEGE EACH ADDITIONAL DEFENDANT'S BREACH AND CAUSAL ROLE].

4. Damages and fault

11. Plaintiff seeks proven past and future medical expense, lost earnings or earning capacity, property loss if applicable, and other economic loss: [CATEGORIES, AMOUNTS, SUPPORT].
12. 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.
13. [ONLY IF FACTS SUPPORT IT:] Plaintiff seeks punitive damages for [FACTS SHOWING OUTRAGEOUS CONDUCT OR RECKLESS INDIFFERENCE], subject to the clear-and-convincing standard, separate amount proceeding, and limits of AS 09.17.020.
14. 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. If more than one party is liable, AS 09.17.080 requires a several-liability judgment based on each liable party's percentage of fault.

5. Prayer for relief

Plaintiff asks for judgment awarding:

1. Economic damages proved at trial;
2. Noneconomic damages within AS 09.17.010;
3. Punitive damages only if paragraph 13 is included and the evidence satisfies AS 09.17.020;
4. Prejudgment and postjudgment interest as allowed by AS 09.30.070, excluding future economic, future noneconomic, and punitive damages from prejudgment interest under subsection (c);
5. Costs and attorney fees to the extent awarded under applicable law and Civil Rule 82; and
6. 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.