Adam F. v. Caitlin B., 551 P.3d 553 (Alaska 2024) – Confirmed that reckless disregard for risk of injury suffices for assault when force is used during an argument. The Court analogized Peter’s push to Adam’s dropping of his partner.

John E. v. Andrea E., 445 P.3d 649 (Alaska 2019) – Addressed extreme corporal punishment under AS 25.24.150(h). Peter relied on John E. to argue that lesser force cannot be assault; the Court distinguished it, emphasising the separate “reasonable & appropriate” test of AS 11.81.430.

S.R.D. v. State, 820 P.2d 1088 (Alaska App. 1991) – Adopted the “totality-of-the-circumstances” approach for assessing parental discipline. The superior court properly applied this framework.

Collateral-Consequences Cases – Reed S., 522 P.3d 182 (Alaska 2022); Peter A., 146 P.3d 991 (Alaska 2006) – Justified review of an expired DVPO due to potential impact on future custody determinations (Williams v. Barbee, 243 P.3d 995 (Alaska 2010)).

Additional authorities (Ledbetter, Jones-Nelson, Martin N., Cooper) supplied standards of review and definitions of culpability.

The Court’s reasoning proceeds in two stages:

1. Assault Analysis.
   • “Physical injury” includes pain (AS 11.81.900(b)(49)). The child’s crying, photograph of scrapes, and father’s own statement that he wanted the child to feel the grandmother’s pain sufficed.
   • “Recklessly” means conscious disregard of a substantial, unjustifiable risk (AS 11.81.900(a)(3)). Beer consumption, anger, and purposeful infliction of pain met this standard.
2. Reasonable-Discipline Defense.
   • The defense requires force that is (a) “nondeadly” and (b) “reasonable and appropriate,” used “to promote the welfare of the child” (AS 11.81.430(a)(1)).
   • The Court stressed that nondeadly force is not automatically reasonable. Purpose and proportionality matter.
   • Here, the push was retributive, aimed at causing equivalent pain, not at constructive discipline. That motive removed the act from statutory protection.

The ruling clarifies Alaska law in several ways:

• Clarified Motive Requirement. Even mild physical acts can be unreasonable if driven by anger or revenge. Future custody and DVPO cases will probe parental intent more deeply.
• Guidance on Corporal Discipline. Trial courts receive explicit validation to consider context (alcohol, anger, language used, removal of siblings, etc.) when evaluating “reasonableness.”
• Broadens Collateral-Consequences Doctrine. Confirms that an expired DVPO can still affect parental rights, ensuring appellate oversight.
• Practical Parenting Effects. Parents are on notice that corporal discipline framed as “demonstrative pain” is unlikely to pass statutory muster.

• Domestic Violence Protective Order (DVPO): A civil order restraining contact when a court finds a respondent committed a domestic-violence crime.
• Preponderance of Evidence: More likely than not; the burden of proof at DVPO hearings, lighter than “beyond a reasonable doubt.”
• Recklessness: Awareness of a serious risk and a decision to ignore it.
• Affirmative Defense: The defendant admits the underlying act but claims a legal justification; the burden shifts to the defendant to prove it.
• Nondeadly Force: Force that ordinarily does not create a risk of death or serious bodily harm.
• Collateral-Consequences Doctrine: Courts may hear a technically moot appeal if the judgment can later influence legal rights (e.g., child-custody presumptions).