Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Contracts
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The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants and dismissing Plaintiff's claims for negligent misrepresentation and intentional interference with a contract, holding that Defendants were entitled to summary judgment.Plaintiff sued Defendants, her adult stepchildren, claiming that they caused their father - and Plaintiff's late husband - to remove Plaintiff as the primary beneficiary of his insurance plan. The district court determined that Plaintiff failed to present evidence to establish any genuine dispute of material fact for trial and awarded summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was proper because Plaintiff failed to establish a dispute of material fact as to whether Defendants supplied false information and as to whether a valid contract existed between her and Defendants. View "Page v. Meyers" on Justia Law

Posted in: Contracts
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The Supreme Court answered in the affirmative a question certified to it by the United States Court of Appeals asking whether an insurance policy is "issued for delivery" or "delivered" under Wyo. Stat. Ann. 26-15-101(a)(ii) even if not copy was conveyed to Wyoming and the police listed only an out-of-state address for the insured.Specifically, the Supreme Court held (1) for purposes of Wyo. Stat. Ann. 26-15-101(a)(ii), an insurance contract is "delivered" in Wyoming if it is actually or constructively delivered in Wyoming, and an insurance contract is "issued for delivery" where the policy was intended to be delivered; and (2) absent an insurance contract unambiguously stating otherwise, if the location of the insured and the location of the risk to be insured are both in Wyoming, an insurance policy is intended to be delivered and is issued for delivery in Wyoming. View "Sinclair Wyoming Refining Co. v. Infrassure, Ltd" on Justia Law

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The Supreme Court dismissed this appeal for want of jurisdiction, holding that no final order had been entered in this matter.The co-personal representatives of the Estate of Gale S. Iverson sued Cheri Eaton, Iverson's former caretaker, seeking to recover property that the Estate alleged Eaton unlawfully transferred to herself. The Estate requested that Eaton be ordered to provide the Estate an accounting. Eaton, in turn, sued the Estate in a separate action for breach of express and implied contract and quantum meruit. The district court consolidated the actions, denied Eaton's claims, and ordered that Eaton provide the Estate an accounting. Eaton appealed. The Supreme Court dismissed the appeal for want of jurisdiction, holding that no final order had been entered in this matter. View "Davidson-Eaton v. Iversen" on Justia Law

Posted in: Contracts
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The Supreme Court reversed the final judgments against Plaintiffs, Australian investors, who sued Gas Sensing Technology Corporation (GSTC), a Wyoming-based oil and gas service company, for payment of loans Plaintiffs made to finance GSTC's operations in Australia, holding that the court erred in dismissing GSTC's counterclaims.The district court dismissed GSTC's counterclaims on grounds that they unduly complicated the action and were untimely filed. The jury found that Plaintiffs had breached the implied covenant of good faith and fair dealing and, therefore, awarded no damages on Plaintiffs' breach of contract claims. The Supreme Court reversed, holding (1) the district court erred in dismissing GSTC's claims on the ground that they unduly complicated the case; and (2) the court erred in failing to give effect to a pleading GSTC filed in federal court and in dismissing GSTC's counterclaims as untimely. View "Jontra Holdings Pty Ltd v. Gas Sensing Technology Corp." on Justia Law

Posted in: Contracts
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In this property dispute, the Supreme Court reversed the judgment of the district court finding largely in favor of Larry Wagoner, holding that the oral contract between the parties in this case was void.Donald Fuger and Wagoner entered into an oral agreement to construct two buildings on a portion of the Fugers' property. When the buildings were completed Wagoner occupied one and rented the other for several years. Fuger and wife later sued Wagoner and his wife seeking to evict them from the property. Wagoner, in turn, sued the Fugers, alleging contract and equitable theories for ownership of one building and the underlying property. The district court held that an enforceable oral contract existed between Fuger and Wagoner and awarded Wagoner $302,234 plus post-judgment interest. The court did not reach Wagoner's equitable claims. The Supreme Court reversed, holding that the district court erred in finding that a valid oral contract between Wagoner and Fuger existed. The Court remanded for consideration of Wagoner's equitable claims. View "Fuger v. Wagoner" on Justia Law

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In this breach of contract action, the Supreme Court affirmed the judgment of the district court awarding APMTG over $35 million in damages and interest, holding that the district court did not err.Denbury Onshore, LLC agreed to deliver certain amounts of helium to APTMG each year. When Denbury failed to deliver the required amounts, it claimed its nonperformance was excused by two force majeure events. The district court concluded that Denbury had failed to show its non-performance was excluded by a force majeure event except for a period of thirty-six days. The Supreme Court affirmed, holding that the district court did not err in (1) deciding Denbury's request to terminate the parties' agreement under the doctrines of frustration of purpose and/or impossibility of performance; (2) deciding that Denbury had failed to prove its nonperformance between April 23, 2013 and December 30, 2013 was excused by a force majeure event; and (3) deciding that Denbury had failed to prove its nonperformance after mid-August of 2014 was excused by a force majeure event. View "Denbury Onshore, LLC v. APMTG Helium LLC" on Justia Law

Posted in: Contracts
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The Supreme Court affirmed the district court's denial of a motion to set aside default judgment against it after it failed to answer a writ of garnishment, holding that, despite certain procedural infirmities, the district court did not err in denying the motion to set aside default judgment.After Monty Elliott obtained a judgment his efforts to collect led to a writ of garnishment of Sonny Pilcher's earnings from Rack's Gentlemen's Club, a business operated by CC Cowboy's Inc. The district court entered default judgment against CC Cowboys. Pilcher filed a motion to vacate default judgment, which the district court denied. The Supreme Court affirmed, holding that CC Cowboys waived its objection to personal jurisdiction by appearing in the proceeding without making that objection. View "Pilcher v. Elliott" on Justia Law

Posted in: Contracts
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The Supreme Court affirmed the decision of the district court using a judgment against Alexander Mantle to set off judgments Alexander and Majorie Mantle had against Ray and Gary Garland and failing to recognize the Mantles' right to the proceeds from a settlement of a third-party action against Karl Killmer and Killmer & Associates (collectively, Killmer), holding that the district court did not err.Specifically, the Supreme Court held (1) Ray and Gary were entitled to use the assigned portions of the judgment against Alexander to satisfy the judgments the Mantles had against them for fraudulent transfers; and (2) the district court did not have jurisdiction to the portion of the Killmer settlement funds not deposited with the district court. View "Mantle v. North Star Energy & Construction LLC" on Justia Law

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The Supreme Court reversed the judgment of the district court dismissing a corporation's (the Corporation) counterclaims after it was sued by two trusts (the Trusts), holding that the district court erred by dismissing the counterclaims.The Trusts sued the Corporation for payment of loans they made to the Corporation to finance its oil and gas service operations in Australia. The Corporation asserted affirmative defenses and counterclaims. The district court dismissed the counterclaims on the grounds that they unduly complicated the action. The jury ruled that the Trusts had breached the implied covenant of good faith and fair dealing and that the Corporation owed reduced damages to one of the trusts. The Supreme Court reversed, holding (1) the district court erred by dismissing the Corporation's counterclaims because Wyo. R. Civ. P. 13 does not authorize courts to dismiss permissible counterclaims simply because they would unduly complicate the action; and (2) on remand, the court must address a few problems with the jury instructions. View "Gas Sensing Technology Corp. v. New Horizon Ventures Pty Ltd" on Justia Law

Posted in: Contracts
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In this contract dispute, the Supreme Court affirmed the order of the district court dismissing H&P Advisory Limited's complaint against Randgold Resources, Limited and Barrick Gold Corporation for lack of personal jurisdiction, holding that the undisputed facts and all reasonable inferences in H&P's favor did not support personal jurisdiction over Defendants in Wyoming.Randgold, a Jersey (Channel Islands) corporation, and Barrick, a Canada corporation, were two of the world's largest gold mining companies. H&P, a United Kingdom private limited company, served as a neutral broker between the two companies in a merger deal. Those involved in the merger met in Jackson, Wyoming to participate in a series of negotiations. Randgold and Barrick subsequently announced the merger but did not list H&P as an advisor and offered to pay H&P a "small fee" for its role in the merger. H&P sued Randgold and Barrick in the Ninth Judicial District in and for Teton County, Wyoming alleging breach of contract. The district court dismissed the complaint on personal jurisdiction grounds. The Supreme Court affirmed, holding that the district court correctly concluded that it lacked specific personal jurisdiction over Defendants. View "H&P Advisory Ltd. v. Randgold Resources Ltd." on Justia Law