Justia Wyoming Supreme Court Opinion Summaries

Appellees, the purported owners of the “Jay Ranch,” brought an action against Appellant to establish a private road across Appellant’s property. While this suit was pending, Appellees were involved in litigation to determine the rightful ownership the Jay Ranch. The district court concluded that Appellees had satisfied the statutory threshold requirements to move forward with their private road claim and granted Appellees temporary access to the road across Appellant’s property. Thereafter, a decision was rendered against Appellees in the litigation to determine ownership of the Jay Ranch. The district court subsequently dismissed the present case for lack of prosecution. Appellant filed a motion for an award of attorney’s fees and a motion for an award of compensation for the temporary road access. The district court denied both motions. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s post-judgment motion for attorney’s fees was not authorized under Wyo. R. Civ. P. 54; and (2) the district court did not have jurisdiction to consider Appellant’s motion for compensation. View "Edsall v. Moore" on Justia Law

Three consolidated cases involved an ongoing dispute over personal property awarded to Megan Golden in her 2012 divorce from Todd Guion. Golden appealed the district court’s order that: (1) rejected her request for a rehearing on a 2012 denial of her motion to find Guion in contempt of court; (2) denied her motion to vacate a February 2015 order following contempt hearings; and (3) granted Guion’s request for sanctions under W.R.C.P. 11. After review, the Supreme Court dismissed two of the cases for lack of jurisdiction, and affirmed the sanctions case because Golden did not file not file timely notices of appeal. View "Golden v. Guion" on Justia Law

Jeff Lokey and Mike Irwin were business partners in two Wyoming businesses. After the parties dissolved their shared business interests, Irwin filed suit against Lokey, alleging that Lokey had materially breached the terms of the agreement. When Lokey did not timely file an answer the district court entered a default judgment against Lokey that included a provision allowing the parties ten days to file objections to the judgment. Lokey filed an objection, which the district court denied. Lokey appealed, challenging the court’s denial of his objections. The Supreme Court dismissed the appeal, holding (1) the Court lacked jurisdiction to entertain the appeal because Lokey did not timely appeal an appealable order; but (2) the Court had jurisdiction to award, and Irwin was entitled to recover, reasonable attorney fees incurred as a result of this appeal. View "Lokey v. Irwin" on Justia Law

Automation & Electronics, Inc. (A&E) and Consolidated Electric Distributors, Inc. (CE) sued for Red Desert Reclamation, LLC for amounts due on their respective contracts. Pursuant to a stipulation between A&E and Red Desert, the district court entered judgment in favor of A&E. CE was later voluntarily dismissed from the case. A&E subsequently filed a motion for leave to amend its complaint to add CSC Group Holdings, LLC and Cate Street Capital, Inc. as defendants and to add alter ego and fraudulent conveyance claims. The district court granted the motion to amend. The district court then entered two default judgments in favor of A&E making CSC, Cate Street and Red Desert jointly and severally liable on Red Desert’s debt to A&E and setting aside as fraudulent a mortgage granted by Red Desert to CSC, thereby allowing A&E to execute on real property to recover on its judgment against Red Desert. The Supreme Court affirmed, holding that the district court did not lose subject matter jurisdiction over A&E’s motion to amend its complaint after signing off on the stipulated judgment in its favor because A&E was allowed to amend its complaint before CE was voluntarily dismissed from the action. View "CSC Group Holdings, LLC v. Automation & Electronics, Inc." on Justia Law

At the heart of these three consolidated appeals was Sky Harbor’s alleged failure to pay rent to the Cheyenne Regional Airport and to leave the Airport premises. Sky Harbor argued that the district court lacked subject matter jurisdiction to decide any of the cases now on appeal. The district court generally ruled in favor of the Airport in all three cases. The Supreme Court affirmed, holding (1) the district and circuit courts did not lack subject matter jurisdiction in the three combined appeals; and (2) the judgments were entered in accordance with the law. View "Sky Harbor Air Serv., Inc. v. Cheyenne Reg’l Airport Bd." on Justia Law

This matter arose following the Supreme Court’s opinion in Wallop Canyon Ranch, LLC v. Goodwyn, in which the Supreme Court affirmed a district court order awarding Scott Goodwyn attorney fees pursuant to Wyo. Stat. Ann. 17-14-1104. Goodwyn subsequently filed a motion to recover appellate attorney fees. The district court denied the application, concluding that Goodwyn was required to file his motion with the Wyoming Supreme Court before the mandate issued. The Supreme Court dismissed Goodwyn’s appeal on the merits, holding that the district court’s order denying Goodwyn’s motion for appellate attorney fees was a correct application of the law. View "Goodwyn v. Wallop" on Justia Law

In 2014, Appellant filed a Wyo. R. Civ. P. 60(b)(4) motion seeking to set aside a 1999 default judgment granting Appellee a divorce. In support of her motion, Appellant alleged that the default judgment was void because the district court lacked jurisdiction to enter the default judgment against her. The circuit court denied the motion, finding that the motion was not filed within a reasonable time. The Supreme Court affirmed, holding (1) the district court erred in rejecting Appellant’s Rule 60(b)(4) motion based solely on Appellant’s delay in filing the motion, as Rule 60(b)’s time limitations do not generally apply to Rule 60(b)(4) motions to set aside a judgment as void; but (2) none of the defects Appellant alleged in the district court’s default judgment rendered the judgment void for lack of jurisdiction. View "Linch v. Linch" on Justia Law

This case concerned a dispute regarding who was entitled to the proceeds of a retirement annuity contract. Plaintiff filed a complaint for declaratory judgment pursuant to the Uniform Declaratory Judgments Act claiming that she was entitled to the proceeds. The circuit court entered summary judgment in favor of Defendant. Plaintiff appealed. The district court did not reach the merits of the case, concluding that the circuit court lacked jurisdiction over the dispute because only a district court has jurisdiction over matters brought under the Declaratory Judgments Act, no matter the amount in controversy. The Supreme Court reversed, holding (1) a cause of action seeking declaratory relief can be within the jurisdiction of the circuit court so long as the circuit court has jurisdiction independent of the declaratory relief requested; and (2) in this case, the circuit court had jurisdiction independent of the declaratory relief sought, and therefore, the court had jurisdiction to decide the declaratory judgment claim. View "Best v. Best" on Justia Law

Accelerated Receivable Solutions (ARS) filed a creditor’s claim against the Estate of Margaret A. Hauf (Estate). The Estate rejected ARS’s claim, filed the notice of rejection in district court, and mailed the rejection notice to ARS via certified mail. The mailed notice was returned to the Estate unclaimed. Approximately four months later, counsel for ARS learned that the postal service had erroneously stamped the the certified mailing unclaimed and returned it to the sender. ARS filed a complaint in district court objecting to the disallowance of its claim and seeking judgment on the claim. The district court dismissed the complaint as time barred. The Supreme Court affirmed, holding that the district court did not err in dismissing ARS’s complaint against the Estate where the Estate strictly complied with the statutory notice requirements in rejecting ARS’s claim and where ARS failed timely to file its complaint after receiving constitutionally adequate notice of the Estate’s rejection of ARS’s claim. View "Accelerated Receivable Solutions v. Hauf" on Justia Law

The State, by and through the State Treasurer of Wyoming and the State Retirement System (collectively, the State), filed this action against Appellees - rating agencies - alleging that the rating agencies were liable for hundreds of millions of dollars in investment losses on mortgage-backed securities during the 2007-2008 financial crisis. The district court granted the rating agencies’ motion to dismiss all claims against them for lack of personal jurisdiction, concluding that the rating agencies did not have sufficient contacts with Wyoming to rise to the level required by the due process clause. The Supreme Court affirmed, holding that the State failed to establish a prima facie case of personal jurisdiction over the rating agencies. View "State v. Moody’s Investors Serv., Inc." on Justia Law