Parker v. Alaska Department of Revenue,
960 P.2d 586 (1998)

Facts: Steve Parker (D), a resident of California, challenges Alaska's personal jurisdiction over him in an action brought by the Alaska Department of Revenue (P), seeking a judgment for paternity and child support. While stationed in Alaska, D engaged in sexual inter-course with an Alaska resident, which allegedly resulted in the birth of a child. The trial court held it could exercise personal jurisdiction over D. D appeals.

Issue: Is conceiving a child in a state sufficient minimum contacts with that state for that state to exercise personal jurisdiction over a party?

Holding: Yes. Judgment affirmed.
The Superior Court, Third Judicial District, Anchorage, entered judgment from which putative father appealed. The Supreme Court held that the trial court properly exercised personal jurisdiction over the father.

Analysis: Appellant father was stationed in Alaska and engaged in sexual intercourse with an Alaska resident, which resulted in the conception of a child. Appellee, state support enforcement division, sought a judgment of paternity and child support, and appellant, a resident of California, challenged the trial court's jurisdiction. The court affirmed the judgment of the trial court and held that specific jurisdiction was justified on the basis of the relationship between appellant, the forum, and the litigation. Appellant purposefully directed his activities at the mother of his child, which resulted in the child's birth. The court held that a person who engaged in sexual intercourse with a resident of Alaska while in Alaska should have foreseen the possibility that a child might be born and that a paternity and support action might be brought. Thus, the court found that appellant had sufficient minimum contacts with Alaska. Further, appellant failed to demonstrate or argue any compelling interest against the exercise of personal jurisdiction.