State, Department of Revenue, Child Support Enforcement Division, Ex Rel. Gerke v. Gerke

OPINION

EASTAUGH, Justice.

I. INTRODUCTION

After repeated attempts to collect child support from David Gerke, the Alaska Child Support Enforcement Division (CSED) reduced the arrearages to final judgment. The superior court conditioned “any” collection of the arrearages judgment for periods more than five years upon a showing of “just and sufficient reasons” for failing to execute within five years, pursuant to AS 09.35.020 and Alaska Civil Rule 69(d).

Because it was error to apply Alaska Civil Rule 69(d) and AS 09.35.020 to administrative, non-judicial collection proceedings, we reverse and…