{"attribution":{"source":"legal.exploreworldai.com","canonical":"https://legal.exploreworldai.com/api/public/v1/judgment-text?id=us:alaska-s19049-2025-09-05","cite_as":"NovaCopilot, legal.exploreworldai.com (https://legal.exploreworldai.com/api/public/v1/judgment-text?id=us:alaska-s19049-2025-09-05)","license":"https://legal.exploreworldai.com/revision","version":"legal-2026-10-17","fingerprint":"ewai:us:e7344b","proof":"sha256:48c4917e2711f48296e75296d190d6b1a5b2b901de65afb47ef733071d1e924d","jurisdiction":"us","lang":"en","publisher":"NovaCopilot by ExploreWorld Legal","terms":"https://legal.exploreworldai.com/om"},"brand_source":"Source: NovaCopilot","item":{"schema_version":"1.0.0","id":"us:alaska-s19049-2025-09-05","jurisdiction":"us","lang":"en","brand_source":"Source: NovaCopilot","brand":{"product":"NovaCopilot","platform":"ExploreWorldAI","infrastructure":"ExploreWorld Legal","infrastructure_url":"legal.exploreworldai.com","legal_entity":"Valkiv Ventures AB","permanent_url":"https://legal.exploreworldai.com/novacopilot","source":"Source: NovaCopilot","powered_by":"Powered by NovaCopilot","license":"https://legal.exploreworldai.com/licensvillkor"},"sections":[{"title":"","paragraphs":["para_1","para_2"]},{"title":"303 K Street, Anchorage, Alaska 99501, phone (907) 264-0608, fax (907) 264-0878, email","paragraphs":["para_4"]},{"title":"THE SUPREME COURT OF THE STATE OF ALASKA","paragraphs":["para_6","para_7","para_8","para_9","para_10","para_11","para_12","para_13","para_14","para_15","para_16","para_17","para_18","para_19","para_20"]},{"title":"Supreme Court No. S-19049","paragraphs":[]},{"title":"Superior Court No. 3AN-24-04303 CI","paragraphs":[]},{"title":"O P I N I O N","paragraphs":[]},{"title":"No. 7784 – September 5, 2025","paragraphs":[]},{"title":"Appeal from the Superior Court of the State of Alaska, Third","paragraphs":["para_26","para_27"]},{"title":"Anchorage, for Appellant. Laura Fox, Senior Assistant","paragraphs":[]},{"title":"Attorney General, Anchorage, and Treg Taylor, Attorney","paragraphs":["para_30","para_31","para_32","para_33"]},{"title":"INTRODUCTION","paragraphs":[]},{"title":"A business appeals the denial of its petition to quash a subpoena to","paragraphs":["para_36","para_37","para_38","para_39","para_40","para_41","para_42","para_43"]},{"title":"FACTS AND PROCEEDINGS","paragraphs":[]},{"title":"A. Facts","paragraphs":[]},{"title":"The Consumer Protection Unit (CPU) of the Attorney General’s Office","paragraphs":["para_47"]},{"title":"State of Alaska under the Unfair Trade Practices and Consumer Protection Act","paragraphs":[]},{"title":"(UTPA).1 In August 2023 the CPU received an anonymous letter alleging that two local","paragraphs":["para_50","para_51","para_52","para_53","para_54"]},{"title":"Joshua Smith, a CPU investigator, requested to open an investigation","paragraphs":["para_56"]},{"title":"Department of Law approved his request. CPU attorneys John Haley and Ian Engelbeck","paragraphs":["para_58"]},{"title":"Although the investigation was approved in August, CPU staff did not act","paragraphs":["para_60","para_61"]},{"title":"1 AS 45.50.471-.561 (declaring “[u]nfair methods of competition and unfair","paragraphs":["para_63","para_64","para_65"]},{"title":"3 Alaska Statute 45.25.440 requires vehicle dealers to include “all dealer","paragraphs":["para_67","para_68"]},{"title":"At the end of November Smith went to Business Doe during the lunch","paragraphs":["para_70","para_71","para_72","para_73","para_74","para_75"]},{"title":"Smith then went to Business Doe’s main vehicle lot. Still recording, he","paragraphs":["para_77","para_78","para_79"]},{"title":"In December the CPU issued a subpoena under AS 45.50.495(b) to","paragraphs":[]},{"title":"Business Doe.4 The subpoena stated, “The Attorney General has reason to believe that","paragraphs":["para_82","para_83","para_84","para_85"]},{"title":"November 30, 2023. The subpoena specifically listed sales contracts, Monroney5 and","paragraphs":["para_87","para_88"]},{"title":"4 The CPU issued a nearly identical subpoena later in December because","paragraphs":["para_90","para_91","para_92"]},{"title":"5 Monroney stickers are uniform labels required by federal law that display","paragraphs":["para_94","para_95","para_96"]},{"title":"In late December Business Doe’s attorney contacted Engelbeck to find out","paragraphs":["para_98"]},{"title":"Doe later asserted that Engelbeck told its lawyer that the subpoena was not based upon","paragraphs":["para_100","para_101"]},{"title":"In early January 2024 Business Doe “demanded” that the CPU withdraw","paragraphs":["para_103","para_104","para_105","para_106","para_107"]},{"title":"B. Proceedings","paragraphs":[]},{"title":"After the January deadline to provide documents passed, Business Doe","paragraphs":["para_110","para_111","para_112","para_113","para_114","para_115","para_116","para_117","para_118"]},{"title":"6 See AS 45.50.471 (declaring deceptive trade practices unlawful and","paragraphs":["para_120"]},{"title":"7 See AS 45.50.495 (authorizing attorney general to request documents and","paragraphs":["para_122","para_123","para_124","para_125","para_126","para_127","para_128","para_129"]},{"title":"Doe was committing unfair or deceptive acts because Engelbeck did not know about","paragraphs":["para_131","para_132","para_133"]},{"title":"Professional Conduct 5.3.9","paragraphs":[]},{"title":"In addition, Business Doe contended that the anonymous complaint letter","paragraphs":["para_136","para_137"]},{"title":"Business Doe also argued that the undercover investigation did not","paragraphs":["para_139","para_140","para_141"]},{"title":"The CPU opposed the petition to quash the subpoena, arguing that it had","paragraphs":["para_143","para_144"]},{"title":"8 See Minutes, S. Judiciary Comm. Hearing on C.S.H.B. 543, 8th Leg., 2d","paragraphs":["para_146"]},{"title":"9 See AS 44.17.010 (authorizing principal executive officer of each state","paragraphs":["para_148"]},{"title":"(authorizing principal executive officer to appoint, supervise, and direct subordinate","paragraphs":["para_150","para_151","para_152","para_153","para_154","para_155","para_156","para_157","para_158","para_159","para_160","para_161"]},{"title":"Business Doe’s website or visited its business. The CPU stressed that the subpoena","paragraphs":["para_163","para_164","para_165"]},{"title":"Finally, the CPU noted that Business Doe had not provided any evidence","paragraphs":["para_167","para_168","para_169","para_170","para_171","para_172"]},{"title":"11 A subpoena duces tecum is a request for the production of documentary","paragraphs":["para_174","para_175"]},{"title":"12 See id. at 541 (requiring administrative subpoenas to be “issued pursuant","paragraphs":["para_177","para_178","para_179","para_180","para_181","para_182"]},{"title":"After finding Business Doe had waived any objection to service by filing the petition,14","paragraphs":["para_184","para_185","para_186","para_187","para_188","para_189"]},{"title":"AS 45.50.495(a) did not apply to the powers listed in AS 45.50.495(b). And it agreed","paragraphs":["para_191","para_192","para_193"]},{"title":"Doe had engaged in deceptive trade practices under the UTPA. The court found that","paragraphs":["para_195"]},{"title":"State had “a legitimate interest in investigating violations in consumer protections","paragraphs":["para_197","para_198"]},{"title":"STANDARD OF REVIEW","paragraphs":[]},{"title":"We review discovery orders, including the denial of a petition to quash a","paragraphs":["para_201","para_202","para_203","para_204","para_205","para_206","para_207","para_208","para_209","para_210","para_211","para_212"]},{"title":"DISCUSSION","paragraphs":[]},{"title":"The parties disagree whether the attorney general is required to have","paragraphs":["para_215","para_216","para_217","para_218"]},{"title":"Under subsection (a) of the statute, if the attorney general “has cause to","paragraphs":["para_220","para_221","para_222","para_223","para_224","para_225","para_226"]},{"title":"18 Id. at 347 (footnote omitted) (citing Nelson-Lizardi v. Lizardi, 49 P.3d","paragraphs":["para_228"]},{"title":"19 AS 45.50.495(a); see also AS 45.50.471(a) (prohibiting deceptive trade","paragraphs":["para_230","para_231"]},{"title":"21 AS 45.50.495(b) (“The attorney general . . . may issue subpoenas to","paragraphs":["para_233","para_234","para_235","para_236","para_237"]},{"title":"Business Doe nonetheless argues that the “cause to believe” standard in","paragraphs":["para_239","para_240","para_241"]},{"title":"(a) by stating “in addition to other powers conferred by this section” the two parts of","paragraphs":["para_243","para_244","para_245","para_246","para_247"]},{"title":"It is not necessary for us to decide whether subsection (b) incorporates the","paragraphs":["para_249","para_250"]},{"title":"AS 45.50.495(b) to authorize the CPU to issue a subpoena. The letter itself accused","paragraphs":["para_252"]},{"title":"The attached email correspondence between an apparent employee of Business Doe and","paragraphs":["para_254"]},{"title":"Although Business Doe suggests that the letter was submitted by someone within the","paragraphs":[]},{"title":"CPU itself, it produced no evidence to support its claim. The letter’s specificity and the","paragraphs":["para_257","para_258"]},{"title":"Business Doe expresses concern that the CPU’s interpretation of the","paragraphs":["para_260"]},{"title":"Business Doe cites the comment in the legislative history to argue that the CPU needs","paragraphs":["para_262"]},{"title":"25 Business Doe also argues that Investigator Smith was unsupervised, but","paragraphs":["para_264","para_265","para_266","para_267","para_268","para_269","para_270","para_271"]},{"title":"The legislative committee’s reference to probable cause27 was not","paragraphs":["para_273","para_274","para_275"]},{"title":"26 Business Doe complains that allowing the CPU to investigate without","paragraphs":["para_277","para_278","para_279","para_280"]},{"title":"27 See Minutes, S. Judiciary Comm. Hearing on C.S.H.B. 543, 8th Leg., 2d","paragraphs":["para_282","para_283"]},{"title":"Alexander, 566 P.3d 268, 284 (Alaska 2025) (“[L]egislative history usually does not","paragraphs":["para_285","para_286","para_287","para_288"]},{"title":"Business Doe compares this case to a Kentucky one in which an appeals","paragraphs":["para_290","para_291","para_292","para_293","para_294"]},{"title":"29 See, e.g., Ariz. Rev. Stat. Ann. § 44-1524(A) (“If the attorney general has","paragraphs":["para_296","para_297","para_298","para_299","para_300","para_301","para_302","para_303","para_304","para_305","para_306","para_307","para_308","para_309","para_310","para_311"]},{"title":"Ann. tit. 9, § 2460(a)(1) (“The Attorney General . . . whenever he or she has reason to","paragraphs":["para_313","para_314","para_315","para_316","para_317","para_318","para_319","para_320","para_321","para_322"]},{"title":"In contrast, the CPU investigated Business Doe for an unfair trade practice","paragraphs":["para_324"]},{"title":"AS 45.50.471. The anonymous letter included an email from an apparent employee of","paragraphs":[]},{"title":"Business Doe engaging in precisely that unfair trade practice: confirming that Business","paragraphs":[]},{"title":"Doe was charging dealer documentation fees on top of its advertised prices. The","paragraphs":["para_328","para_329","para_330","para_331"]},{"title":"CONCLUSION","paragraphs":["para_333","para_334"]},{"title":"34 Business Doe also argues the superior court erred by failing to conduct an","paragraphs":["para_336","para_337","para_338"]}],"paragraphs":[{"text":"Notice: This opinion is subject to correction before publication in the PACIFIC REPORTER.","paragraph_id":"para_1"},{"text":"Readers are requested to bring errors to the attention of the Clerk of the Appellate Courts,","paragraph_id":"para_2"},{"text":"303 K Street, Anchorage, Alaska 99501, phone (907) 264-0608, fax (907) 264-0878, email","paragraph_id":"para_3"},{"text":"corrections@akcourts.gov.","paragraph_id":"para_4"},{"text":"THE SUPREME COURT OF THE STATE OF ALASKA","paragraph_id":"para_5"},{"text":"BUSINESS DOE, LLC,","paragraph_id":"para_6"},{"text":"Appellant,","paragraph_id":"para_7"},{"text":"v.","paragraph_id":"para_8"},{"text":"STATE OF ALASKA,","paragraph_id":"para_9"},{"text":"Appellee.","paragraph_id":"para_10"},{"text":")","paragraph_id":"para_11"},{"text":")","paragraph_id":"para_12"},{"text":")","paragraph_id":"para_13"},{"text":")","paragraph_id":"para_14"},{"text":")","paragraph_id":"para_15"},{"text":")","paragraph_id":"para_16"},{"text":")","paragraph_id":"para_17"},{"text":")","paragraph_id":"para_18"},{"text":")","paragraph_id":"para_19"},{"text":")","paragraph_id":"para_20"},{"text":"Supreme Court No. S-19049","paragraph_id":"para_21"},{"text":"Superior Court No. 3AN-24-04303 CI","paragraph_id":"para_22"},{"text":"O P I N I O N","paragraph_id":"para_23"},{"text":"No. 7784 – September 5, 2025","paragraph_id":"para_24"},{"text":"Appeal from the Superior Court of the State of Alaska, Third","paragraph_id":"para_25"},{"text":"Judicial District, Anchorage, Laura Hartz, Judge.","paragraph_id":"para_26"},{"text":"Appearances: Rachel B. Lauesen, Lauesen Law Team, LLC,","paragraph_id":"para_27"},{"text":"Anchorage, for Appellant. Laura Fox, Senior Assistant","paragraph_id":"para_28"},{"text":"Attorney General, Anchorage, and Treg Taylor, Attorney","paragraph_id":"para_29"},{"text":"General, Juneau, for Appellee.","paragraph_id":"para_30"},{"text":"Before: Carney, Chief Justice, and Borghesan, Henderson,","paragraph_id":"para_31"},{"text":"and Pate, Justices.","paragraph_id":"para_32"},{"text":"CARNEY, Chief Justice.","paragraph_id":"para_33"},{"text":"INTRODUCTION","paragraph_id":"para_34"},{"text":"A business appeals the denial of its petition to quash a subpoena to","paragraph_id":"para_35"},{"text":"produce business records. The subpoena was issued by the consumer protection","paragraph_id":"para_36"},{"text":"division of the attorney general’s office in connection with its investigation into","paragraph_id":"para_37"},{"text":"reported unfair and deceptive business practices. Because there was cause to issue the","paragraph_id":"para_38"},{"text":"subpoena, it was authorized by AS 45.50.495(b). The subpoena also specified the","paragraph_id":"para_39"},{"text":"-2- 7784","paragraph_id":"para_40"},{"text":"particular documents to be produced, as required by the same law. The superior court","paragraph_id":"para_41"},{"text":"did not abuse its discretion by denying the petition to quash the subpoena and we affirm","paragraph_id":"para_42"},{"text":"its order.","paragraph_id":"para_43"},{"text":"FACTS AND PROCEEDINGS","paragraph_id":"para_44"},{"text":"A. Facts","paragraph_id":"para_45"},{"text":"The Consumer Protection Unit (CPU) of the Attorney General’s Office","paragraph_id":"para_46"},{"text":"investigates unfair and deceptive trade practices and files legal actions on behalf of the","paragraph_id":"para_47"},{"text":"State of Alaska under the Unfair Trade Practices and Consumer Protection Act","paragraph_id":"para_48"},{"text":"(UTPA).1 In August 2023 the CPU received an anonymous letter alleging that two local","paragraph_id":"para_49"},{"text":"car dealerships, one of which was Business Doe,2 were charging documentation fees on","paragraph_id":"para_50"},{"text":"top of advertised prices in violation of AS 45.25.440.3 Attached to the letter was an","paragraph_id":"para_51"},{"text":"email exchange between a sender using an address listing “@[businessdoe.com]” and","paragraph_id":"para_52"},{"text":"another individual, confirming that Business Doe charged dealer documentation fees","paragraph_id":"para_53"},{"text":"on top of its advertised prices.","paragraph_id":"para_54"},{"text":"Joshua Smith, a CPU investigator, requested to open an investigation","paragraph_id":"para_55"},{"text":"regarding the complaint in the letter. The chief of the Special Litigation Section in the","paragraph_id":"para_56"},{"text":"Department of Law approved his request. CPU attorneys John Haley and Ian Engelbeck","paragraph_id":"para_57"},{"text":"were copied on the request and approval.","paragraph_id":"para_58"},{"text":"Although the investigation was approved in August, CPU staff did not act","paragraph_id":"para_59"},{"text":"on it until October. A paralegal periodically took video screenshots of advertisements","paragraph_id":"para_60"},{"text":"on Business Doe’s website.","paragraph_id":"para_61"},{"text":"1 AS 45.50.471-.561 (declaring “[u]nfair methods of competition and unfair","paragraph_id":"para_62"},{"text":"or deceptive acts or practices in the conduct of trade or commerce” unlawful and","paragraph_id":"para_63"},{"text":"authorizing attorney general power to investigate).","paragraph_id":"para_64"},{"text":"2 We use a pseudonym for the business.","paragraph_id":"para_65"},{"text":"3 Alaska Statute 45.25.440 requires vehicle dealers to include “all dealer","paragraph_id":"para_66"},{"text":"fees and costs” in their advertised prices.","paragraph_id":"para_67"},{"text":"-3- 7784","paragraph_id":"para_68"},{"text":"At the end of November Smith went to Business Doe during the lunch","paragraph_id":"para_69"},{"text":"hour posing as a potential customer. He first visited a location he believed was its place","paragraph_id":"para_70"},{"text":"of business. He spoke to a Business Doe employee who told him that the main place","paragraph_id":"para_71"},{"text":"of business was across the street. Smith recorded the conversation and asked the","paragraph_id":"para_72"},{"text":"employee if vehicle prices were their actual prices or if there would be an additional","paragraph_id":"para_73"},{"text":"documentation fee. The employee responded that there would be an additional","paragraph_id":"para_74"},{"text":"documentation fee.","paragraph_id":"para_75"},{"text":"Smith then went to Business Doe’s main vehicle lot. Still recording, he","paragraph_id":"para_76"},{"text":"asked a second employee there, “How hard are you guys on your prices?” The","paragraph_id":"para_77"},{"text":"employee responded that Business Doe might negotiate reasonable offers and that in","paragraph_id":"para_78"},{"text":"addition to any negotiated price there would be “a doc[ument] and DMV fee.”","paragraph_id":"para_79"},{"text":"In December the CPU issued a subpoena under AS 45.50.495(b) to","paragraph_id":"para_80"},{"text":"Business Doe.4 The subpoena stated, “The Attorney General has reason to believe that","paragraph_id":"para_81"},{"text":"[Business Doe] may have violated Alaska Statute 45.25.440 by charging dealer fees or","paragraph_id":"para_82"},{"text":"costs that were not included in advertised prices. The Attorney General is conducting","paragraph_id":"para_83"},{"text":"a confidential investigation into the matter.” The subpoena directed Business Doe to","paragraph_id":"para_84"},{"text":"provide copies of documents for all vehicles sold between October 12, 2023, and","paragraph_id":"para_85"},{"text":"November 30, 2023. The subpoena specifically listed sales contracts, Monroney5 and","paragraph_id":"para_86"},{"text":"dealer window stickers, and all advertisements for all vehicles sold. The subpoena set","paragraph_id":"para_87"},{"text":"an early January deadline to provide the documents.","paragraph_id":"para_88"},{"text":"4 The CPU issued a nearly identical subpoena later in December because","paragraph_id":"para_89"},{"text":"the first had been delivered to a relative of Business Doe’s registered agent rather than","paragraph_id":"para_90"},{"text":"the agent. The second subpoena was signed by an assistant attorney general; the earlier","paragraph_id":"para_91"},{"text":"one was signed by Smith.","paragraph_id":"para_92"},{"text":"5 Monroney stickers are uniform labels required by federal law that display","paragraph_id":"para_93"},{"text":"information for consumers, including the final price by the vehicle manufacturer. See","paragraph_id":"para_94"},{"text":"AS 45.25.400(b)(1).","paragraph_id":"para_95"},{"text":"-4- 7784","paragraph_id":"para_96"},{"text":"In late December Business Doe’s attorney contacted Engelbeck to find out","paragraph_id":"para_97"},{"text":"why it had received a subpoena and to object to Smith’s undercover activity. Business","paragraph_id":"para_98"},{"text":"Doe later asserted that Engelbeck told its lawyer that the subpoena was not based upon","paragraph_id":"para_99"},{"text":"a complaint but was issued because the attorney general “has an interest in the industry","paragraph_id":"para_100"},{"text":"in general as you can see from [a recent similar case].”","paragraph_id":"para_101"},{"text":"In early January 2024 Business Doe “demanded” that the CPU withdraw","paragraph_id":"para_102"},{"text":"its subpoena, arguing that “an interest in the industry in general” was not sufficient to","paragraph_id":"para_103"},{"text":"authorize an investigation into its business practices and that the subpoena was not","paragraph_id":"para_104"},{"text":"valid. Business Doe requested instead that the CPU consult with it regarding","paragraph_id":"para_105"},{"text":"compliance with AS 45.25.440 and asked that the CPU agree not to take further","paragraph_id":"para_106"},{"text":"investigative or enforcement action. The CPU declined.","paragraph_id":"para_107"},{"text":"B. Proceedings","paragraph_id":"para_108"},{"text":"After the January deadline to provide documents passed, Business Doe","paragraph_id":"para_109"},{"text":"filed a petition in superior court to quash the subpoena. It argued that the CPU must","paragraph_id":"para_110"},{"text":"have “cause to believe” that a violation of AS 45.50.4716 has occurred or will occur","paragraph_id":"para_111"},{"text":"before it can authorize an investigation under AS 45.50.495.7 Business Doe claimed","paragraph_id":"para_112"},{"text":"that AS 45.50.495(a) and (b) must be read as: “ ‘[i]f the Attorney General has cause to","paragraph_id":"para_113"},{"text":"believe . . . ’ the AG may investigate.” It argued that the two statutory sections had to","paragraph_id":"para_114"},{"text":"be interpreted together so that the attorney general must have “cause to believe” a","paragraph_id":"para_115"},{"text":"business engaged in, was engaging in, or was going to “commit a violation of consumer","paragraph_id":"para_116"},{"text":"protection laws before it has any power to investigate since the information acquired","paragraph_id":"para_117"},{"text":"could be used for criminal proceedings.”","paragraph_id":"para_118"},{"text":"6 See AS 45.50.471 (declaring deceptive trade practices unlawful and","paragraph_id":"para_119"},{"text":"defining “unfair methods of competition” and “unfair or deceptive acts or practices”).","paragraph_id":"para_120"},{"text":"7 See AS 45.50.495 (authorizing attorney general to request documents and","paragraph_id":"para_121"},{"text":"property for examination and authorizing issuance of subpoenas to witnesses or for","paragraph_id":"para_122"},{"text":"physical evidence “to aid an investigation or inquiry”).","paragraph_id":"para_123"},{"text":"-5- 7784","paragraph_id":"para_124"},{"text":"Business Doe, relying on a comment in legislative committee minutes,","paragraph_id":"para_125"},{"text":"asserted that the statute “[g]rant[ed] investigative powers to the Attorney General to","paragraph_id":"para_126"},{"text":"obtain books and records on short notice when there is probable cause to believe that","paragraph_id":"para_127"},{"text":"fraud has been committed.”8 Business Doe argued, based upon its December","paragraph_id":"para_128"},{"text":"conversation with Engelbeck, that the CPU did not have “cause to believe” Business","paragraph_id":"para_129"},{"text":"Doe was committing unfair or deceptive acts because Engelbeck did not know about","paragraph_id":"para_130"},{"text":"the complaint letter. Citing AS 44.17.010 and AS 44.17.040, Business Doe also argued","paragraph_id":"para_131"},{"text":"that the investigation was unauthorized because “[t]here was . . . no supervision,","paragraph_id":"para_132"},{"text":"direction, and control of Investigator Smith” as was required by Alaska Rule of","paragraph_id":"para_133"},{"text":"Professional Conduct 5.3.9","paragraph_id":"para_134"},{"text":"In addition, Business Doe contended that the anonymous complaint letter","paragraph_id":"para_135"},{"text":"could not establish “cause to believe.” It argued that the letter lacked any indicia of","paragraph_id":"para_136"},{"text":"reliability and alleged that it had been written by CPU staff.","paragraph_id":"para_137"},{"text":"Business Doe also argued that the undercover investigation did not","paragraph_id":"para_138"},{"text":"establish the requisite “cause to believe.” It asserted that undercover investigations","paragraph_id":"para_139"},{"text":"were not included in the list of the attorney general’s investigatory powers and therefore","paragraph_id":"para_140"},{"text":"the CPU was acting outside the scope of its authority.10","paragraph_id":"para_141"},{"text":"The CPU opposed the petition to quash the subpoena, arguing that it had","paragraph_id":"para_142"},{"text":"authority to issue the subpoena and none of Business Doe’s arguments undermined its","paragraph_id":"para_143"},{"text":"authority. It asserted that the subpoena was an administrative subpoena, which “is","paragraph_id":"para_144"},{"text":"8 See Minutes, S. Judiciary Comm. Hearing on C.S.H.B. 543, 8th Leg., 2d","paragraph_id":"para_145"},{"text":"Sess. (Apr. 16, 1974) (testimony of Attorney General Norman Gorsuch).","paragraph_id":"para_146"},{"text":"9 See AS 44.17.010 (authorizing principal executive officer of each state","paragraph_id":"para_147"},{"text":"department to delegate functions to subordinate officers and employees); AS 44.17.040","paragraph_id":"para_148"},{"text":"(authorizing principal executive officer to appoint, supervise, and direct subordinate","paragraph_id":"para_149"},{"text":"department staff); Alaska R. Prof. Conduct 5.3 (lawyers’ supervisory responsibilities","paragraph_id":"para_150"},{"text":"regarding nonlawyer assistance).","paragraph_id":"para_151"},{"text":"10 See AS 45.50.495.","paragraph_id":"para_152"},{"text":"-6- 7784","paragraph_id":"para_153"},{"text":"similar, but not identical to a subpoena duces tecum,”11 and that as a result, the court’s","paragraph_id":"para_154"},{"text":"oversight was limited to whether the subpoena was overbroad or sought irrelevant","paragraph_id":"para_155"},{"text":"material.12 The CPU argued that its subpoena was lawful under AS 45.50.495(b)","paragraph_id":"para_156"},{"text":"because it was reasonably designed to aid a good-faith investigation and would aid the","paragraph_id":"para_157"},{"text":"investigation or inquiry. The CPU asserted it was conducting a good-faith investigation","paragraph_id":"para_158"},{"text":"because the letter and email attachment were sufficient to provide a good-faith basis to","paragraph_id":"para_159"},{"text":"investigate under the low standard required for an administrative subpoena.13 It argued","paragraph_id":"para_160"},{"text":"that the letter and email attachment alone were sufficient even before it monitored","paragraph_id":"para_161"},{"text":"Business Doe’s website or visited its business. The CPU stressed that the subpoena","paragraph_id":"para_162"},{"text":"was reasonably designed to aid its investigation of Business Doe’s practices and that","paragraph_id":"para_163"},{"text":"the documents requested were in furtherance of its evaluation of whether Business Doe","paragraph_id":"para_164"},{"text":"was conducting deceptive trade practices.","paragraph_id":"para_165"},{"text":"Finally, the CPU noted that Business Doe had not provided any evidence","paragraph_id":"para_166"},{"text":"that the letter and email attachment were not authentic. And it denied Business Doe’s","paragraph_id":"para_167"},{"text":"claim that Smith was “unsupervised,” noting that the chief assistant attorney general","paragraph_id":"para_168"},{"text":"had given written approval of the Business Doe investigation. The CPU argued that","paragraph_id":"para_169"},{"text":"undercover investigations were especially necessary for consumer protection because","paragraph_id":"para_170"},{"text":"consumers were often unaware of UTPA violations and would find it difficult to","paragraph_id":"para_171"},{"text":"identify violations by themselves.","paragraph_id":"para_172"},{"text":"11 A subpoena duces tecum is a request for the production of documentary","paragraph_id":"para_173"},{"text":"evidence and is governed by Alaska Rule of Civil Procedure 45(b). See Tesoro","paragraph_id":"para_174"},{"text":"Petroleum Corp. v. State, 42 P.3d 531, 540 (Alaska 2002).","paragraph_id":"para_175"},{"text":"12 See id. at 541 (requiring administrative subpoenas to be “issued pursuant","paragraph_id":"para_176"},{"text":"to lawful authority,” “relevant to the inquiry for which it is issued,” and to “contain[]","paragraph_id":"para_177"},{"text":"adequate specification of the documents to be produced” (quoting Matanuska Maid,","paragraph_id":"para_178"},{"text":"Inc. v. State, 620 P.2d 182, 189 (Alaska 1980))).","paragraph_id":"para_179"},{"text":"13 See id.","paragraph_id":"para_180"},{"text":"-7- 7784","paragraph_id":"para_181"},{"text":"The superior court denied Business Doe’s petition to quash the subpoena.","paragraph_id":"para_182"},{"text":"After finding Business Doe had waived any objection to service by filing the petition,14","paragraph_id":"para_183"},{"text":"it held that the subpoena was authorized under AS 45.50.495(b) and that Business Doe","paragraph_id":"para_184"},{"text":"had not demonstrated the subpoena was irrelevant to the inquiry for which it was issued","paragraph_id":"para_185"},{"text":"or that it did not adequately specify the documents to be produced.15 The court found","paragraph_id":"para_186"},{"text":"that the subpoena was part of a good-faith investigation into potential UTPA violations","paragraph_id":"para_187"},{"text":"and that no warrant was necessary for Smith to visit Business Doe’s property because","paragraph_id":"para_188"},{"text":"it was open to the public. The court determined that the “cause to believe” standard in","paragraph_id":"para_189"},{"text":"AS 45.50.495(a) did not apply to the powers listed in AS 45.50.495(b). And it agreed","paragraph_id":"para_190"},{"text":"with the CPU that even if the “cause to believe” standard applied, the subpoena should","paragraph_id":"para_191"},{"text":"not be quashed. The court concluded that the letter and email attachment were enough","paragraph_id":"para_192"},{"text":"to meet this “low bar” and that they were sufficient to find cause to believe that Business","paragraph_id":"para_193"},{"text":"Doe had engaged in deceptive trade practices under the UTPA. The court found that","paragraph_id":"para_194"},{"text":"the subpoena was reasonably designed16 to aid the CPU’s investigation and that the","paragraph_id":"para_195"},{"text":"State had “a legitimate interest in investigating violations in consumer protections","paragraph_id":"para_196"},{"text":"laws.”","paragraph_id":"para_197"},{"text":"Business Doe appeals.","paragraph_id":"para_198"},{"text":"STANDARD OF REVIEW","paragraph_id":"para_199"},{"text":"We review discovery orders, including the denial of a petition to quash a","paragraph_id":"para_200"},{"text":"subpoena, under the deferential abuse of discretion standard,17 and will reverse the","paragraph_id":"para_201"},{"text":"superior court’s decision “only when, after reviewing the whole record, we are left with","paragraph_id":"para_202"},{"text":"14 The subpoena was not properly served on Business Doe.","paragraph_id":"para_203"},{"text":"15 See Tesoro Petroleum Corp., 42 P.3d at 541 (quoting Matanuska Maid,","paragraph_id":"para_204"},{"text":"620 P.2d at 189).","paragraph_id":"para_205"},{"text":"16 See AS 45.50.495(b).","paragraph_id":"para_206"},{"text":"17 See Lee v. State, 141 P.3d 342, 346 (Alaska 2006) (citing Coulson v.","paragraph_id":"para_207"},{"text":"Marsh & McLennan, Inc., 973 P.2d 1142, 1146 (Alaska 1999)).","paragraph_id":"para_208"},{"text":"-8- 7784","paragraph_id":"para_209"},{"text":"a definite and firm conviction that the superior court erred. But we apply our","paragraph_id":"para_210"},{"text":"independent judgment in deciding the legal question whether the superior court weighed","paragraph_id":"para_211"},{"text":"the appropriate factors in issuing a discovery order.”18","paragraph_id":"para_212"},{"text":"DISCUSSION","paragraph_id":"para_213"},{"text":"The parties disagree whether the attorney general is required to have","paragraph_id":"para_214"},{"text":"“cause to believe” a violation of the UTPA has occurred under AS 45.50.495(a) before","paragraph_id":"para_215"},{"text":"it may issue a subpoena for records under AS 45.50.495(b). We need not decide that","paragraph_id":"para_216"},{"text":"question in this case because we conclude that, regardless of whether the statute requires","paragraph_id":"para_217"},{"text":"it, there was sufficient “cause” for the subpoena in this case.","paragraph_id":"para_218"},{"text":"Under subsection (a) of the statute, if the attorney general “has cause to","paragraph_id":"para_219"},{"text":"believe that a person has engaged in, is engaging in, or is about to engage in a deceptive","paragraph_id":"para_220"},{"text":"trade practice,” the attorney general may act.19 The attorney general may request certain","paragraph_id":"para_221"},{"text":"statements filed under oath, examine a person under oath, examine property, books and","paragraph_id":"para_222"},{"text":"documents, and may also impound samples of property.20 Subsection (b) describes the","paragraph_id":"para_223"},{"text":"attorney general’s subpoena power.21 For example, the attorney general may issue a","paragraph_id":"para_224"},{"text":"subpoena to witnesses or for the production of physical evidence.22 The “cause to","paragraph_id":"para_225"},{"text":"believe” language that is included in subsection (a) is not present in subsection (b).23","paragraph_id":"para_226"},{"text":"18 Id. at 347 (footnote omitted) (citing Nelson-Lizardi v. Lizardi, 49 P.3d","paragraph_id":"para_227"},{"text":"236, 239 (Alaska 2002)).","paragraph_id":"para_228"},{"text":"19 AS 45.50.495(a); see also AS 45.50.471(a) (prohibiting deceptive trade","paragraph_id":"para_229"},{"text":"practices).","paragraph_id":"para_230"},{"text":"20 AS 45.50.495(a)(1)-(5).","paragraph_id":"para_231"},{"text":"21 AS 45.50.495(b) (“The attorney general . . . may issue subpoenas to","paragraph_id":"para_232"},{"text":"require the attendance of witnesses or the production of documents or other physical","paragraph_id":"para_233"},{"text":"evidence, administer oaths, and conduct hearings to aid an investigation or inquiry.”).","paragraph_id":"para_234"},{"text":"22 Id.","paragraph_id":"para_235"},{"text":"23 See id.","paragraph_id":"para_236"},{"text":"-9- 7784","paragraph_id":"para_237"},{"text":"Business Doe nonetheless argues that the “cause to believe” standard in","paragraph_id":"para_238"},{"text":"subsection (a) applies to subsection (b), and that the CPU must have “cause to believe”","paragraph_id":"para_239"},{"text":"that a deceptive trade practice has occurred, is occurring, or will occur before it can","paragraph_id":"para_240"},{"text":"issue a subpoena. Business Doe asserts that because subsection (b) refers to subsection","paragraph_id":"para_241"},{"text":"(a) by stating “in addition to other powers conferred by this section” the two parts of","paragraph_id":"para_242"},{"text":"the statute must be interpreted as a single, harmonious unit.24 It further asserts that not","paragraph_id":"para_243"},{"text":"requiring a “cause to believe” standard to issue a subpoena while requiring it before","paragraph_id":"para_244"},{"text":"documents can be examined or copied “would lead to an absurd result,” because the","paragraph_id":"para_245"},{"text":"point of a subpoena is to require production of records specifically so they can be","paragraph_id":"para_246"},{"text":"examined.25","paragraph_id":"para_247"},{"text":"It is not necessary for us to decide whether subsection (b) incorporates the","paragraph_id":"para_248"},{"text":"“cause to believe” standard from AS 45.50.495(a). Whether the standard applies or not,","paragraph_id":"para_249"},{"text":"the anonymous letter that the CPU received provided sufficient basis under","paragraph_id":"para_250"},{"text":"AS 45.50.495(b) to authorize the CPU to issue a subpoena. The letter itself accused","paragraph_id":"para_251"},{"text":"Business Doe of charging dealer documentation fees in addition to its advertised prices.","paragraph_id":"para_252"},{"text":"The attached email correspondence between an apparent employee of Business Doe and","paragraph_id":"para_253"},{"text":"an inquiring consumer provided additional support for the letter’s accusations.","paragraph_id":"para_254"},{"text":"Although Business Doe suggests that the letter was submitted by someone within the","paragraph_id":"para_255"},{"text":"CPU itself, it produced no evidence to support its claim. The letter’s specificity and the","paragraph_id":"para_256"},{"text":"reasonable inferences to be drawn from it provide sufficient indicia of reliability to","paragraph_id":"para_257"},{"text":"further support the CPU’s authority to issue the subpoena.","paragraph_id":"para_258"},{"text":"Business Doe expresses concern that the CPU’s interpretation of the","paragraph_id":"para_259"},{"text":"statute as requiring less than probable cause will give it undue power to investigate.","paragraph_id":"para_260"},{"text":"Business Doe cites the comment in the legislative history to argue that the CPU needs","paragraph_id":"para_261"},{"text":"24 See id.","paragraph_id":"para_262"},{"text":"25 Business Doe also argues that Investigator Smith was unsupervised, but","paragraph_id":"para_263"},{"text":"the record shows that Smith received written approval to open the investigation.","paragraph_id":"para_264"},{"text":"-10- 7784","paragraph_id":"para_265"},{"text":"probable cause to investigate and refers us to other state courts’ interpretation of their","paragraph_id":"para_266"},{"text":"statutes. And it suggests that because other states have required “cause to believe” to","paragraph_id":"para_267"},{"text":"issue a subpoena or begin a consumer protection investigation, Alaska’s legislature","paragraph_id":"para_268"},{"text":"must also have intended that it be required.26 But because the legislature did not require","paragraph_id":"para_269"},{"text":"that the “cause” required by AS 45.50.495(a) be “probable cause” or “good cause”, we","paragraph_id":"para_270"},{"text":"will not write that language into the statute.","paragraph_id":"para_271"},{"text":"The legislative committee’s reference to probable cause27 was not","paragraph_id":"para_272"},{"text":"included in the statute that was enacted.28 And the statutes that our sister courts have","paragraph_id":"para_273"},{"text":"interpreted to require good cause to issue administrative subpoenas are worded","paragraph_id":"para_274"},{"text":"differently than AS 45.50.495. Those statutes include specific language requiring","paragraph_id":"para_275"},{"text":"26 Business Doe complains that allowing the CPU to investigate without","paragraph_id":"para_276"},{"text":"requiring it to have good cause will violate its right against self-incrimination. But the","paragraph_id":"para_277"},{"text":"subpoena itself stated “[i]f you believe a document requested in this Subpoena may","paragraph_id":"para_278"},{"text":"implicate you in a crime, you may exercise your Fifth Amendment right not to be","paragraph_id":"para_279"},{"text":"compelled in a criminal case to be a witness against yourself.”","paragraph_id":"para_280"},{"text":"27 See Minutes, S. Judiciary Comm. Hearing on C.S.H.B. 543, 8th Leg., 2d","paragraph_id":"para_281"},{"text":"Sess. (Apr. 16, 1974) (testimony of Attorney General Norman Gorsuch).","paragraph_id":"para_282"},{"text":"28 See AS 45.50.495; see also State, Dep’t of Educ. & Early Dev. v.","paragraph_id":"para_283"},{"text":"Alexander, 566 P.3d 268, 284 (Alaska 2025) (“[L]egislative history usually does not","paragraph_id":"para_284"},{"text":"override the plain terms of a statute.”).","paragraph_id":"para_285"},{"text":"-11- 7784","paragraph_id":"para_286"},{"text":"reasonable cause.29 Other state courts’ interpretations of statutes that use language such","paragraph_id":"para_287"},{"text":"as “reasonable cause” or “good cause” therefore do not provide definitive guidance.30","paragraph_id":"para_288"},{"text":"Business Doe compares this case to a Kentucky one in which an appeals","paragraph_id":"para_289"},{"text":"court quashed an administrative subpoena relating to a defective product","paragraph_id":"para_290"},{"text":"investigation.31 In that case the court held that a letter with attachments alleging a","paragraph_id":"para_291"},{"text":"defective product was not sufficient “reason to believe” that the state’s consumer","paragraph_id":"para_292"},{"text":"protection law had been violated.32 The Kentucky court relied on the absence of","paragraph_id":"para_293"},{"text":"complaints from customers or “affidavits of anyone who tested appellants’ product and","paragraph_id":"para_294"},{"text":"29 See, e.g., Ariz. Rev. Stat. Ann. § 44-1524(A) (“If the attorney general has","paragraph_id":"para_295"},{"text":"reasonable cause to believe that a person has engaged in, is engaging in or is about to","paragraph_id":"para_296"},{"text":"engage in any practice or transaction which is in violation of this article . . . he may . . .","paragraph_id":"para_297"},{"text":"[r]equire such person to file on such forms as he prescribes a statement or report in","paragraph_id":"para_298"},{"text":"writing, under oath, as to all the facts and circumstances concerning the sale . . .","paragraph_id":"para_299"},{"text":"[e]xamine under oath any person in connection with the sale . . . [and] [e]xamine any","paragraph_id":"para_300"},{"text":"merchandise or sample thereof, or any record, book, document, account or paper as he","paragraph_id":"para_301"},{"text":"may deem necessary.”); Colo. Rev. Stat. Ann. § 6-1-108(1) (“When the attorney general","paragraph_id":"para_302"},{"text":". . . has reasonable cause to believe that a person . . . has engaged in or is engaging in a","paragraph_id":"para_303"},{"text":"deceptive trade practice . . . the attorney general . . . may issue subpoenas to require the","paragraph_id":"para_304"},{"text":"attendance of witnesses or the production of documents, administer oaths, conduct","paragraph_id":"para_305"},{"text":"hearings in aid of any investigation or inquiry.”); S.D. Codified Laws § 37-1-11.1 (“If","paragraph_id":"para_306"},{"text":"the attorney general has reasonable cause to believe that a person has information or is","paragraph_id":"para_307"},{"text":"in possession, custody, or control of any document or other tangible object relevant to","paragraph_id":"para_308"},{"text":"an investigation for violation of this chapter, he may serve upon the person . . . a written","paragraph_id":"para_309"},{"text":"demand to appear and be examined under oath, to answer written interrogatories under","paragraph_id":"para_310"},{"text":"oath, and to produce the document or object for inspection and copying.”); Vt. Stat.","paragraph_id":"para_311"},{"text":"Ann. tit. 9, § 2460(a)(1) (“The Attorney General . . . whenever he or she has reason to","paragraph_id":"para_312"},{"text":"believe any person to be . . . in violation of . . . this title . . . may examine . . . any books,","paragraph_id":"para_313"},{"text":"records, papers, memoranda, and physical objects . . . and may demand written","paragraph_id":"para_314"},{"text":"responses under oath to questions bearing upon each alleged violation.”).","paragraph_id":"para_315"},{"text":"30 See, e.g., id.","paragraph_id":"para_316"},{"text":"31 Ward v. Commonwealth ex rel. Stephens, 566 S.W.2d 426 (Ky. App.","paragraph_id":"para_317"},{"text":"1978).","paragraph_id":"para_318"},{"text":"32 Id. at 428-29.","paragraph_id":"para_319"},{"text":"-12- 7784","paragraph_id":"para_320"},{"text":"found it defective” to conclude that the investigating agency lacked reason to believe","paragraph_id":"para_321"},{"text":"the product was defective.33","paragraph_id":"para_322"},{"text":"In contrast, the CPU investigated Business Doe for an unfair trade practice","paragraph_id":"para_323"},{"text":"— charging additional documentation fees in addition to its advertised prices — under","paragraph_id":"para_324"},{"text":"AS 45.50.471. The anonymous letter included an email from an apparent employee of","paragraph_id":"para_325"},{"text":"Business Doe engaging in precisely that unfair trade practice: confirming that Business","paragraph_id":"para_326"},{"text":"Doe was charging dealer documentation fees on top of its advertised prices. The","paragraph_id":"para_327"},{"text":"anonymous letter itself appears to be a consumer complaint. Attached to it was apparent","paragraph_id":"para_328"},{"text":"proof of the unfair trade practice identified in the letter. The superior court did not","paragraph_id":"para_329"},{"text":"abuse its discretion by concluding that the letter provided a sufficient basis for the CPU","paragraph_id":"para_330"},{"text":"to open an investigation into Business Doe’s practice.34","paragraph_id":"para_331"},{"text":"CONCLUSION","paragraph_id":"para_332"},{"text":"We AFFIRM the superior court’s order.","paragraph_id":"para_333"},{"text":"33 Id. at 428.","paragraph_id":"para_334"},{"text":"34 Business Doe also argues the superior court erred by failing to conduct an","paragraph_id":"para_335"},{"text":"evidentiary hearing to determine whether the anonymous complaint letter provided","paragraph_id":"para_336"},{"text":"reasonable grounds for an investigation. 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