S.B. v. State Alaska

Ronald E. Gudmundson and Steven Knutson were convicted by a jury of wanton waste of a big game animal. AS 16.30.010(a). The court sentenced each defendant to fifteen days imprisonment with all but three and one-half days suspended and imposed fines of $1,250 each. We affirmed the convictions, but remanded for the imposition of a legal sentence. Knutson v. State, 736 P.2d 775 (Alaska App. 1987). On remand, Gudmundson and Knutson moved to vacate their conviction on jurisdictional grounds, i.e., that the statute under which they were convicted was void because it violated due process. Such a claim may be brought at any time because it involves a claim that the complaint "does not charge a crime." Alaska R. Crim. P. 12(b)(2); Gray v. State, 525 P.2d 524, 527 n.8, 9 (Alaska 1974). We affirm.