## Facts

- Sharon Ranney and Gary Stone began a romantic relationship in 1995 and cohabited until Stone’s death in April 1999.
- The couple shared a joint checking account, appeared together in a local telephone listing, and jointly purchased equipment (including a sawmill, crane, and truck).
- Stone named Ranney the primary beneficiary of his life insurance policy; Ranney intermittently worked but relied on Stone’s income to maintain her standard of living.
- Friends and Ranney described an intent to marry; Ranney testified Stone bought a ring in 1997 and proposed in March 1999.
- Stone died in a work-related accident while employed by Whitewater Engineering.
- Ranney sought workers’ compensation death benefits as Stone’s “unmarried spouse.”
- Whitewater Engineering and its insurer controverted the claim, asserting Ranney was not a “widow” because she was never legally married to Stone.
- The Alaska Workers’ Compensation Act provides death benefits to a deceased employee’s “widow or widower.”

## Issues

1. Whether the Workers’ Compensation Act’s death-benefit provision for a “widow or widower” (and the statutory definition of “wife”) includes an unmarried cohabiting partner.
2. Whether denying death benefits to an unmarried cohabitant substantially burdens the Alaska constitutional right to privacy in maintaining an intimate, unmarried relationship.
3. Whether limiting death benefits to legally married spouses violates Alaska equal protection guarantees.

## Decision

- The Alaska Supreme Court affirmed the denial of benefits.
- The Act’s terms “widow” and “widower” require a valid legal marriage and do not include unmarried cohabitants, even with long-term cohabitation and intent to marry.
- Denying spousal death benefits to an unmarried cohabitant did not substantially burden the constitutional privacy right.
- The marriage-based eligibility line was fairly and substantially related to the Act’s goals of quick, efficient, fair, and predictable benefits at reasonable cost, satisfying equal protection.

## Legal Principles

- Statutory references to “widow” and “widower” in workers’ compensation death-benefit provisions are presumed to incorporate the ordinary meaning of legal marriage unless the legislature clearly indicates otherwise.
- Conditioning statutory spousal benefits on legal marriage does not, without a substantial burden, infringe the Alaska constitutional privacy right to maintain an intimate relationship outside marriage.
- Under Alaska equal protection analysis, a classification is valid when it is fairly and substantially related to legitimate governmental objectives; administrability and predictability may justify marriage as an objective eligibility criterion in benefit schemes.

## Conclusion

The court held that workers’ compensation death benefits reserved for a “widow or widower” are limited to legally married spouses, and that excluding unmarried cohabitants neither substantially burdens constitutional privacy interests nor violates equal protection given the legislature’s administrability and cost-control objectives.


Ranney v. Whitewater Eng’g, 122 P.3d 214 (Alaska 2005)