joined by COMPTON, Justice, dissenting in part.
The framers of the Alaska Constitution established the superior court as the trial court of general jurisdiction for our state. Alaska Const, art. IV, § 8. One purpose of the superior court is to serve as an institution to which the people of Alaska may resort when they believe that they have suffered a legal wrong. Crushing attorney’s fees such as the $76,000 award which today’s opinion approves so seriously limit this purpose that they are, in my opinion, fundamentally at odds with our constitution.
The general right of access to civil courts was recognized by this court in Bush v. Reid, 516 P.2d 1215, 1218-21 (Alaska 1973), where we invalidated on due process and equal protection grounds a statute which precluded a person on parole from bringing a civil action. In so doing, we relied primarily on Boddie v. Connecticut, 401 U.S. 371, 91 S.Ct. 780, 28 L.Ed.2d 113 (1971), in which the United States Supreme Court held that indigents could not be deprived of access to divorce courts by the imposition of filing fees which they were unable to pay. Because the parolee’s lawsuit in Bush arose out of a personal injury suffered in an automobile accident, it was distinguishable from the divorce litigation in Boddie. We found, however, that this distinction should not dilute the force of the Boddie rationale, especially as a matter of state constitutional law. Bush at 1219-20. Similarly, in Patrick v. Lynden Transport, Inc., 765 P.2d 1375 (Alaska 1988), we recognized the right of access to the courts as declared in Boddie and rejected the view that Boddie should be limited to divorce cases. Id. at 1378-79.
We have also recognized the right of access to the courts in the specific context of court awarded attorney’s fees. In Malvo v. J.C. Penney Co., 512 P.2d 575, 588 (Alaska 1973), we reversed a $10,500 award which represented the prevailing litigant’s full attorney’s fees. After noting that the purpose of Civil Rule 82 “is to partially compensate a prevailing party for the costs to which he has been put in the litigation in which he was involved,” id. at 587 (quoting Preferred General Agency of Alaska, Inc. v. Raffetto, 391 P.2d 951, 954 (Alaska 1964)), we stated:
If a successful litigant were to receive full reimbursement for all expenses incurred in the case with no requirement of justification and no consideration of the “good faith” nature of the unsuccessful party’s claim or defense, there would be a serious detriment to the judicial system. For where in order to seek judicial remedies, a plaintiff must risk liability for the full amount of attorney’s fees the other side sees fit to incur, it takes little imagination to foresee that the size of a party’s bank account will have a major impact on his access to the courts.
Id. (emphasis supplied). We then cited Boddie and quoted the following language from that opinion:
[A] cost requirement, valid on its face, may offend due process because it operates to foreclose a particular party’s opportunity to be heard. The State’s obligations under the Fourteenth Amendment are not simply generalized ones; rather, the State owes to each individual that process which, in light of the values of a free society, can be characterized as due.
Malvo at 587. Having referred to the constitutional issue, we declined to reach it because, as we put it, “it is ‘manifestly unreasonable’ to establish a policy under Civil Rule 82 that would enable a store *6owner to receive such a sizeable allowance for attorney's fees against a party who has brought suit in good faith.” Id.
Although the discussion in Malvo was directed to a trial court’s award of full fees, much of the rationale is also applicable to substantial awards of partial fees against litigants of limited resources. If a $10,500 attorney’s fee award is so great as to “foreclose a particular party’s opportunity to be heard” it has that effect independent of whether it represents the prevailing party’s full, or merely partial, fees.
Former Chief Justice Boochever recognized this in his dissent in Sloan v. Atlantic Richfield Co., 552 P.2d 157, 161-62 (Alaska 1976). In Sloan, the trial court ordered the widow of a deceased construction worker to pay attorney’s fees of $10,-750 in a wrongful death case, about half of the full fees requested by the prevailing party. Id. at 161. Citing the reasoning of Malvo, Mrs. Sloan argued that the award against her was so large it would have a chilling effect on the use of our courts by many holding bona fide claims. A majority of the court rejected this argument, noting, “we do not view this case as falling within an exceptional category.” Sloan at 161. Chief Justice Boochever dissented, stating that if Mrs. Sloan had “[fjoreknowledge that such a sizeable sum would be awarded as attorney’s fees in the event of her losing” it “could well have constituted an impediment to access to the courts preventing litigation of an issue which she had every right to have resolved.” Id. at 162. Noting the concern expressed in Malvo “that access to the courts might be governed by the size of one’s bank account,” id., Chief Justice Boochever stated that in applying Civil Rule 82, trial courts “must give consideration to the nature of the claim and the need for making courts available to resolve disputes without the imposition of intolerable burdens.” Id.
I agree with Chief Justice Boochever that in determining what fees constitute a “reasonable amount” under Civil Rule 82(a)(1), trial courts must consider whether the award is so great that it imposes an intolerable burden on a losing litigant which, in effect, denies the litigant’s right of access to the courts.
The guidelines for making such a determination are not easy to express. Chief Justice Boochever in Sloan indicated that “other than stating broad policy considerations,” he was “unable to delineate specific guidelines for a trial judge to follow in awarding attorney’s fees.” Id. He then settled on the “admittedly ... arbitrary figure” of $2500 as “the maximum that I think could be awarded without unduly limiting access to the courts under the facts of this case.” Id.
While it is difficult to prescribe guidelines for the trial courts to follow in this area, trial courts should at least consider whether an award may be so onerous to the losing litigant that it unduly limits the constitutional right of access. Over time, the process of case-by-case adjudication will yield more specific directions. I suggest presently that in wrongful discharge claims the award of attorney’s fees not exceed some fraction of the former employee’s annual income.
This case is only one of a number of cases which we have had occasion to review recently involving very large awards of attorney’s fees. See Zeilinger v. SOHIO Alaska Petroleum Co., 823 P.2d 653 (Alaska 1992) (superior court awarded $80,-470 to employer in wrongful discharge case — reversed on appeal as excessive); Van Huff v. Sohio Alaska Petroleum Co., appeal pending, No. S-4373 (superior court awarded $117,251 in attorney’s fees in favor of employer in wrongful discharge case). In each of these cases an individual citizen believing in good faith that his or her legal rights had been violated pursued dispute resolution in the superior court in the manner contemplated by our constitution. The citizen lost and was subjected to a financially ruinous award of attorney’s fees.
If the superior court is to serve its constitutional purpose as a forum available to all the people, superior court judges must consider whether an award of attorney’s fees will impair the constitutional right of access to the courts. In the present case it *7is evident that no such consideration was given. Therefore, I would reverse the award of attorney’s fees and remand for further proceedings in accordance with the views expressed herein.