Alaska Court System: Alaska Supreme Court Opinion No. 7812, S-19351, Humphrey v. Reges

On June 5th, 2026, the Alaska Supreme Court issued an opinion in Humphrey v. Srijis. For the first time, the Supreme Court had to decide whether a plaintiff in a civil lawsuit can be excluded from court for disrupting the proceedings. A man sued his neighbors over a property line dispute. The case went to trial, and the man represented himself. Many people represent themselves in civil cases.

He repeatedly interrupted proceedings, argued with the judge, and ignored the judge's explanations and instructions.

After twice requiring the man to participate by video conference and warning him that he would not be allowed to participate in the trial unless he behaved better, the judge excluded the man from trial. The trial continued without him, and the neighbors won the case.

The man appealed to the Alaska Supreme Court. He argued that he had a right to be present for the trial of his lawsuit.

The United States and Alaska constitutions guarantee due process of law.

The right to due process basically boils down to the right to fair treatment under the law. Due process includes the opportunity to be heard and to present one's side of the case in court. Due process includes a right to be present in court. But the right to be present is not absolute. In cases where someone is accused of a crime, the right to be in court is very strong.

Even then, if a person is too disruptive, that person can be removed. In a civil case like this one, the right to be present is not as strong as in a criminal case. The court must balance a person's right to be there against the other side's right to a fair trial. The court must also warn the person before removing him from trial.

In this situation, the man was given many warnings, but he still made it impossible for the trial to continue. Removing him from the trial was a last resort that was necessary to make sure the defendants had a fair trial. For this reason, the Supreme Court held that the Superior Court did not abuse its discretion when it removed him. The man also made other arguments, but he did not provide any legal or factual support for his arguments. Even self-represented litigants must provide more than just a simple statement to have their claims heard.

The Supreme Court held that those arguments were waived by insufficient briefing and did not consider those other arguments in its decision.