## Facts

- Steve D. Parker, later a California resident, was stationed in Ketchikan, Alaska, in 1978 as a member of the U.S. Coast Guard.
- While in Alaska, Parker had sexual intercourse with an Alaska resident.
- The intercourse resulted in the conception and birth of a child who resided in Alaska.
- The Alaska Department of Revenue, Child Support Enforcement Division (CSED), filed an action in Alaska superior court to establish paternity and obtain a child support order for the child.
- Parker moved to dismiss for lack of personal jurisdiction, arguing Alaska lacked authority to hale him into its courts.
- The superior court denied the motion and proceeded; Parker appealed.

## Issues

1. Whether Alaska courts may constitutionally exercise specific personal jurisdiction over a nonresident putative father in a paternity and child support action based on his sexual intercourse in Alaska resulting in conception of an Alaska-resident child.
2. Whether Alaska’s long-arm statute authorizes jurisdiction to the full extent permitted by federal due process.
3. Whether an inconvenient-forum argument, raised for the first time in a reply brief, should be considered and, if so, defeats jurisdiction.

## Decision

- The Alaska Supreme Court affirmed.
- Alaska’s long-arm statute permits personal jurisdiction to the limits of the Fourteenth Amendment’s Due Process Clause.
- Parker’s in-state conduct—voluntary sexual intercourse in Alaska causing conception of an Alaska-resident child—constituted sufficient minimum contacts for specific jurisdiction because the paternity and support claims arose from that contact.
- Exercising jurisdiction was consistent with fair play and substantial justice because Parker had fair notice that his conduct could subject him to suit in Alaska.
- The court rejected Parker’s inconvenient-forum argument because it was raised only in the reply brief and lacked a showing of undue burden or that key witnesses or evidence were located in California.

## Legal Principles

- Alaska’s catch-all long-arm provision authorizes jurisdiction to the maximum extent allowed by federal due process.
- Due process permits specific jurisdiction when the defendant has minimum contacts with the forum and the claim arises out of or relates to those contacts, such that suit is foreseeable and fair.
- Minimum contacts must be based on the defendant’s purposeful conduct in the forum; jurisdiction cannot rest solely on the unilateral actions of others.
- A single in-forum act can support specific jurisdiction when it creates a substantial connection to the forum and directly gives rise to the litigation.
- Late-raised forum objections may be rejected, and a party asserting inconvenience must show concrete burdens or displaced evidence and witnesses.

## Conclusion

The court held that Alaska could exercise specific personal jurisdiction over a nonresident putative father in a paternity and child support action where his voluntary sexual intercourse in Alaska resulted in conception of an Alaska-resident child, and the claims directly stemmed from that in-state conduct.


Parker v. State, Dep’t of Revenue, Child Support Enf’t Div., 960 P.2d 586 (Alaska 1998)