Justia Wyoming Supreme Court Opinion Summaries

Scott Drewry, a former police sergeant with the Greybull Police Department, left his position following an internal investigation into his conduct during a DUI investigation and other disciplinary issues. After his resignation, Drewry and the Town of Greybull entered into a settlement agreement that included a non-disparagement clause prohibiting the Town and Chief Brenner from making negative statements about Drewry regarding the investigation, termination, or resignation. Later, when Drewry was offered employment with the Basin Police Department, Chief Brenner issued a memorandum to Greybull officers and local officials, stating that Drewry had a history of deception and would not be considered a credible witness in Greybull investigations. Drewry sued for breach of the settlement agreement, defamation per se, and intentional infliction of emotional distress.The District Court of Big Horn County granted summary judgment to Chief Brenner and the Town on all claims. The court found that the non-disparagement clause only covered the blood draw investigation and that the memorandum was truthful and conditionally privileged. It also concluded that Chief Brenner was entitled to qualified immunity, precluding the tort claims, and that there was insufficient evidence of extreme and outrageous conduct for the emotional distress claim.The Supreme Court of Wyoming reviewed the case de novo. It held that qualified immunity barred Drewry’s claims for defamation per se and intentional infliction of emotional distress against both Chief Brenner and the Town, affirming summary judgment on those claims. However, the court found that the phrase “the investigation” in the settlement agreement’s non-disparagement clause was ambiguous, creating genuine issues of material fact about its scope and whether the memorandum breached the agreement. The court reversed the summary judgment on the breach of contract claim and remanded for further proceedings. View "Drewry v. Brenner" on Justia Law

A woman and her long-term partner jointly purchased a duplex in Florida, signing both a promissory note and a mortgage as joint obligors and joint tenants with rights of survivorship. The note required monthly payments and a $100,000 balloon payment. After making all monthly payments, they failed to pay the balloon payment when due. The partner died shortly thereafter, and the woman became the sole owner of the property. The lender sent a default notice, and the woman entered into a forbearance agreement but did not pay the balloon payment. The lender filed a creditor’s claim against the deceased partner’s estate, which was rejected, leading the lender to sue the estate for the unpaid amount.The District Court of Fremont County, Wyoming, found the estate liable for the full balloon payment and associated costs, and also found the woman jointly liable as a co-obligor. The estate then sought contribution from the woman, arguing she should pay her share of the debt. After a bench trial, the district court determined that both the woman and the estate were each responsible for 50% of the balloon payment and related fees, applying Florida’s doctrine of equitable contribution. The court rejected the woman’s arguments that she should not be liable due to alleged inequitable conduct by the estate or because the deceased partner had intended to pay the balloon payment himself.On appeal, the Supreme Court of Wyoming reviewed the district court’s application of Florida law and its equitable determinations. The Supreme Court affirmed the lower court’s decision, holding that the woman was jointly liable for 50% of the balloon payment and associated costs. The court found no abuse of discretion in the district court’s application of the doctrine of equitable contribution, its rejection of the unclean hands defense, or its allocation of attorneys’ fees and costs. View "Hutton v. Dykes" on Justia Law

Several individuals formed a corporation, each contributing initial capital and later making additional cash contributions to meet the company’s needs. These later contributions were documented as promissory notes, including three notes issued to one founder, which were subsequently held by a trust after his death. The notes specified a 24-month term, a fixed interest rate, and repayment terms, but did not explicitly state they were payable on demand. After the founder’s death, the trust demanded payment on the notes, but the company refused, arguing the notes were not yet due, were actually capital contributions, or were subordinate to other shareholder loans.The District Court of Albany County dismissed claims by other shareholders seeking priority repayment, finding no justiciable controversy, and resolved the remaining issues on summary judgment. The court determined the notes were loans, not capital contributions, and that all founders’ notes should be repaid equitably if any were repaid. However, it found the notes were not immediately due and payable, as they lacked a demand provision, and denied the trust’s request for immediate payment. The court did award attorney fees to the trust under the terms of the notes.The Supreme Court of Wyoming reviewed the case and reversed the district court’s finding that the notes were not due and payable, holding that the notes matured after 24 months and were enforceable at that time. The court affirmed that the notes were loans, not capital contributions, and declined to give priority to other shareholder loans, finding no contractual basis for subordination. The court also affirmed the award of attorney fees to the trust and upheld the dismissal of the other shareholders’ claims for lack of a justiciable controversy. The case was remanded for entry of judgment in favor of the trust and determination of reasonable attorney fees and costs. View "King v. Sheesley" on Justia Law

Barbie Jean Schwinn and Deborah Schwinn Bailey filed a lawsuit against Robert Schwinn, TJ Schwinn, and Terry Ann Palazzo to wind up and terminate the Ignaz Schwinn Family Partnership Co. The district court found that the appellants wrongfully dissociated from the partnership, there were no grounds to terminate or wind up the partnership, and the appellants could no longer participate in the management of the partnership. The court granted the appellants a lien against the partnership’s assets for their interests, to be satisfied when the partnership eventually wound up.The district court held a bench trial and dismissed the appellants' claims for breach of contract, breach of fiduciary duty, and breach of the duty of good faith and fair dealing. The court also dismissed the appellants' claims to dissolve and wind up the partnership, finding it was a partnership for a definite term or particular undertaking under Illinois law. The court determined the appellants' dissociation was wrongful and that they were not entitled to payment for their interests until the completion of the undertaking. The court denied the appellees' other counterclaims.The Wyoming Supreme Court reviewed the case and found that the partnership was an at-will partnership, not one for a particular undertaking. The court held that the appellants' dissociation was not wrongful and that their withdrawal triggered the dissolution and winding up of the partnership under Section 801(1) of the Revised Uniform Partnership Act (RUPA). The court reversed the district court's decision and remanded the case for further proceedings to determine if the partnership agreement varied the RUPA's default rules and whether winding up was required under Section 801(5)(iii) due to a deadlock in management. The court also instructed the district court to determine if judicial supervision of the winding up was warranted. View "Schwinn v. Schwinn" on Justia Law

Rick Holloway and John Hoskin entered into a Commercial Sales Agreement to purchase the UXU Resort Ranch from Hidden Creek Outfitters, LLC. The sale included a special use permit from the U.S.D.A. Forest Service, which required a bridge inspection and load test before transfer. Due to the inspection's delay, the parties postponed closing and placed $200,000 in escrow for bridge-related expenses. After inspections, Park County Title released the escrow funds to Hidden Creek without H&H's consent, despite unresolved bridge issues.The District Court of Park County found that Hidden Creek and H&H each breached the implied covenant of good faith and fair dealing, and Park County Title breached the escrow agreement by releasing funds without H&H's approval. However, the court determined H&H failed to prove actual damages with sufficient certainty, awarding only nominal damages. The court also denied attorney’s fees to all parties.The Supreme Court of Wyoming reviewed the case and affirmed the district court's findings. The court held that H&H did not prove actual damages because the inspections did not conclusively identify necessary or required repairs. The court also upheld the denial of attorney’s fees, finding no abuse of discretion, as both parties bore some fault in the litigation. The Supreme Court denied any attorney’s fees associated with the appeal. View "Holloway v. Hidden Creek Outfitters, LLC" on Justia Law

In 2023, Basin Authority, a Wyoming Child Support Agency, notified Rodolfo P. Munoz that he was in arrears on his child support obligation and began garnishing his social security. Mr. Munoz filed a complaint against the State of Wyoming, the Wyoming Department of Family Services (DFS), and some of its employees, as well as Basin Authority and several of its employees. He alleged breach of contract and violations of due process under 42 U.S.C. § 1983. The district court dismissed Mr. Munoz’s complaint after a hearing.The district court of Big Horn County granted the motions to dismiss filed by the State Defendants and the Basin Authority Defendants. The court found that Mr. Munoz had not made allegations against the State Defendants and that they were not subject to suit under § 1983 because they are not “persons” within the meaning of the statute. The court also found that a breach of contract claim is not actionable under § 1983 and that the alleged agreement was void and unenforceable. Mr. Munoz’s objection and response to the State Defendants’ proposed order on the motion to dismiss and his motion for reconsideration were denied.The Supreme Court of Wyoming reviewed the case and summarily affirmed the district court’s decision. The court noted that Mr. Munoz failed to comply with the Wyoming Rules of Appellate Procedure and did not present cogent arguments supported by pertinent authority. The court emphasized that even pro se litigants must adhere to procedural rules and present coherent arguments. The court concluded that summary affirmance was appropriate due to the deficiencies in Mr. Munoz’s brief and his failure to present relevant legal arguments. View "Munoz v. State of Wyoming" on Justia Law

Vernon Black sued Kari Winfield for breach of contract, while Winfield and Samuel Robinson counterclaimed for unjust enrichment against Black. Winfield and Robinson performed various tasks for Black, including constructing fences, branding cattle, and boarding livestock, without receiving compensation or credit towards Winfield's debt to Black. Black had previously secured a judgment against Winfield for $25,828.52 for unpaid legal expenses.The District Court of Fremont County held a bench trial and found that none of the parties established their claims. Specifically, the court found that Winfield and Robinson did not prove their unjust enrichment claims because they failed to show they reasonably notified Black of their expectation of payment and did not prove damages. Winfield and Robinson appealed the decision.The Supreme Court of Wyoming reviewed the case and found that the district court erred in its findings. The Supreme Court determined that the circumstances reasonably notified Black that Winfield and Robinson expected to be compensated for their work. The court noted that Black had a history of paying Winfield for her work, and both Winfield and Robinson directly addressed their expectation of payment with Black on several occasions. Additionally, the nature and quantity of the work performed by Winfield and Robinson indicated that they expected compensation.The Supreme Court also found that Winfield and Robinson proved damages for their day labor, hot shot fees, and boarding and feeding Black's livestock, totaling $22,793.60. The court reversed the district court's decision and remanded the case for entry of judgment in favor of Winfield and Robinson. View "Robinson v. Black" on Justia Law

Chesapeake Exploration, LLC (Chesapeake) and Morton Production Company, LLC (Morton) entered into a joint operating agreement for oil and gas development in Converse County, Wyoming. Morton sued Chesapeake for breach of contract, violation of the Wyoming Royalty Payment Act (WRPA), and conversion after Chesapeake adjusted Morton’s ownership interest and withheld production proceeds. Chesapeake counterclaimed for breach of contract, unjust enrichment, and breach of the implied covenant of good faith and fair dealing. The district court granted summary judgment in favor of Morton.Chesapeake appealed, challenging the district court’s summary judgment on Morton’s breach of contract claim, the supplemental decision on Chesapeake’s counterclaims and affirmative defenses, and the determination that Chesapeake violated the WRPA. The Wyoming Supreme Court reviewed the case.The Wyoming Supreme Court affirmed the district court’s decision. It held that Chesapeake breached the contract by adjusting Morton’s ownership interest and billing for costs beyond the twenty-four-month limitation period specified in the 1985 COPAS Form, which was incorporated into the joint operating agreement. The court found the language in the COPAS Form unambiguous and declined to consider extrinsic evidence. The court also upheld the district court’s use of Rule 60(a) to correct a clerical error in its original order and found that Chesapeake’s counterclaims were properly dismissed as they were rendered moot by the summary judgment on Morton’s claims. Additionally, the court ruled that Chesapeake violated the WRPA by withholding production proceeds without placing the disputed funds in escrow, as required by the statute. View "Chesapeake Exploration, LLC, v. Morton Production Company, LLC" on Justia Law

Eiden Construction, LLC (Eiden) entered into a subcontract with Hogan & Associates Builders, LLC (Hogan) for earthwork and utilities on a school construction project. Hogan sued Eiden and its bonding company, AMCO Insurance Company (AMCO), for breach of contract, claiming Eiden failed to complete its work, including draining sewage lagoons and constructing a fire pond. Eiden counterclaimed for unpaid work, arguing it was not responsible for draining the lagoons and that Hogan did not comply with the subcontract’s notice and opportunity to cure provisions. AMCO argued it was not liable under the performance bond because Eiden did not breach the subcontract and Hogan did not provide proper notice.The District Court of Uinta County found for Hogan on the claim regarding the sewage lagoons but not on other claims, ruling AMCO was not liable under the bond due to lack of notice. Eiden and Hogan both appealed. Eiden argued the court erred in finding it responsible for draining the lagoons and in awarding Hogan damages billed to an associated company. Hogan contended the court erred in not awarding damages for other work and in its calculation of prejudgment interest.The Wyoming Supreme Court affirmed the lower court’s decision. It held Eiden breached the subcontract by not draining the lagoons and that Hogan was entitled to recover costs for supplementing Eiden’s work. The court found Eiden’s late completion of the septic system justified Hogan’s directive to expedite lagoon drainage. It also ruled Hogan properly paid the supplemental contractors, despite invoices being sent to an associated company. The court rejected Hogan’s claims for additional damages, concluding Eiden complied with the notice to cure provisions for the fire pond and other work. The court also upheld the lower court’s calculation of prejudgment interest, applying the offset before calculating interest. View "Hogan & Associates Builders, LLC v. Eiden Construction, LLC" on Justia Law

Appellee filed a complaint against Appellant alleging breach of written agreements for the lease of oil storage tanks. During the bench trial, the district court amended the complaint to include an oral guarantee to pay for the leases, which Appellant was not allowed to rebut. The court found Appellant breached the oral guarantee and awarded damages to Appellee.The District Court of Campbell County initially found in favor of Appellee, determining that Appellant breached the oral guarantee and awarded $114,537.56 in damages. Appellant raised multiple issues on appeal, including the admission of evidence, the application of the statute of frauds, and the effect of a settlement with a co-defendant.The Supreme Court of Wyoming reviewed the case and found that the district court did not abuse its discretion in admitting various exhibits into evidence. The court also held that the statute of frauds defense was waived as it was not raised at trial. Additionally, the court found that the settlement with the co-defendant did not preclude Appellee from pursuing claims against Appellant.However, the Supreme Court of Wyoming determined that the district court abused its discretion by not allowing Appellant to testify regarding the oral guarantee. The court affirmed the district court's rulings on the other issues but reversed and remanded the case for the limited purpose of allowing Appellant to testify about the oral guarantee. The remand is specifically for reconsideration of the personal guarantee and to provide both parties an opportunity to introduce evidence on that issue. View "Sorum v. Sikorski" on Justia Law