Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Contracts
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The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of the Jackson Hole Airport Board and dismissing Appellants' petition for declaratory judgment challenging the validity of an asset purchase agreement between the Board and Jackson Hole Aviation, holding that airport boards have the statutory authority to issue revenue bonds to fund the purchase of intangible property, including goodwill. Appellants were two entities interested in providing services at Jackson Hole Airport and individuals dissatisfied with the Airport's current services. Appellants brought this action claiming that the purchase agreement between the Board and Jackson Hole Aviation, the current service provider at the Airport, exceeded the Board's statutory authority because the Board could not acquire intangible assets using revenue bond funding. The district court concluded that the term "other property" in Wyo. Stat. Ann. 10-5-101(a) authorized the use of revenue bonds for purchases of both tangible and intangible property. The Supreme Court affirmed, holding that section 10-5-101(a) authorized purchases of both tangible and intangible property and that the district court correctly determined that goodwill is intangible property included in the term "other property" found in section 10-5-101(a). View "Herrick v. Jackson Hole Airport Board" on Justia Law

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In this breach of contract case the Supreme Court affirmed the judgment of the district court denying Appellant's Wyo. R. Civ. P. 60(b) motion, holding that neither documents in a party's possession nor public records in existence at the time of trial are newly discovered evidence if, with due diligence, they could have been discovered prior to trial. In its rule 60(b) motion Appellant argued that two pieces of evidence - one of which it possessed and the other which was a matter of public record at the time of trial - constituted newly discovered evidence. The trial court denied the motion. Appellant appealed, arguing that it was not for a lack of due diligence that it did not discover the documents in its physical possession or data available on a website prior to trial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in finding the evidence was not newly discovered because Appellant failed to exercise due diligence. View "SWC Production, Inc. v. Wold Energy Partners, LLC" on Justia Law

Posted in: Contracts
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The Supreme Court affirmed the judgment of the district court dismissing Finley Resources, Inc.'s complaint against EP Energy E&P Company on the grounds that the forum-selection clause contained in the contract between the parties required Finley to file its suit in Texas, holding that the district court did not abuse its discretion in declining to exercise jurisdiction based on the forum-selection clause. On appeal, Finley argued that the district court abused its discretion in dismissing Finley's lawsuit because the declaratory judgment, quiet title, and adverse possession claims did not arise from the parties' contract and, even if the equitable causes of action arose from the contract, the Texas courts lacked subject matter jurisdiction to consider the claims. The Supreme Court disagreed, holding (1) Finley's equitable claims were matters in connection with the contract and were subject to the forum-selection clause; and (2) Finley's claims will necessarily be resolved by the Texas court's determination of its contractual rights. View "Finley Resources, Inc. v. EP Energy E&P Co." on Justia Law

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In this breach of contract and breach of warranty case the Supreme Court affirmed the judgment of the district court granting Shelly Besel's motion for summary judgment and dismissing Shelly from the litigation with prejudice, holding that Shelly was properly dismissed from the litigation. Appellants hired Leonard Besel to remodel their home. Prior to completing the project Leonard terminated the contract. Appellants brought this action naming Shelly as a defendant and alleging that Shelly was a partner of her husband's contracting business. Shelly moved to dismiss herself from the lawsuit, disavowing any partnership interest in her husband's business. The district court granted Shelly's motion. The Supreme Court affirmed, holding that no material issue of fact existed based on the evidence as to Shelly's status vis a vis the business, and therefore, the record supported the district court's ruling dismissing Shelly from the litigation. View "Norris v. Besel" on Justia Law

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The Supreme Court affirmed the order of the district court entering partial summary judgment against Rex Rammell on all his claims against his former employer, Mountainaire Animal Clinic, P.C., its president, and its office manager except Rammell's breach of express contract claim and then dismissing that claim as a sanction for willful obstruction of discovery and fraud upon the court, holding that the district court did not err. Specifically, the Court held (1) deficiencies in Rammell's certification did not mandate dismissal of his appeal; (2) defects in Rammell's notice of appeal did not mandate dismissal; (3) the district court did not err in entering summary judgment against Rammell on his tortious interference claim; and (4) the district court did not abuse its discretion in dismissing Rammell's breach of express contract claim as a sanction for discovery violations. View "Rammell v. Mountainaire Animal Clinic, P.C." on Justia Law

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In this appeal brought by Alex Mantle and Marjorie Mantle the Supreme Court affirmed in part and reversed and remanded in part the district court's decision as to various post-trial issues in ongoing litigation arising from a soured business deal. The Court held (1) the district court lacked subject matter jurisdiction to offset the judgments when that issue was pending in the Supreme Court in Mantle I; (2) with respect to Killmer Settlement Funds, (a) there was no reviewable order in the record regarding whether the Garlands had standing to assert a direct claim against Karl Killmer, and (b) the Mantles did not have a superior security interest in the Killmer Settlement Funds by operation of the “general intangibles” clause of the FNB security agreement; (3) the district court did nor when it awarded North Star Energy & Construction, LLC's attorneys, The Kuker Group, their attorney fees from a portion of the Killmer Settlement Funds; and (4) the district court did not err when it issued a nunc pro tunc order that removed Marjorie Mantle’s name from the order that disbursed the Killmer Settlement Funds. View "Mantle v. North Star Energy & Construction LLC" on Justia Law

Posted in: Business Law, Contracts
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The Supreme Court affirmed the district court’s order on summary judgment motions and order after bench trial in this dispute arising from an ill-conceived business conveyance plan during a downturn in the oil market, holding that the district court did not err or abuse its discretion in any respect. Three Garland brothers, who had separate entities providing specialized services to the oil industry, formed a company with their companies as members and the Garlands individually as members. Alex Mantle was president of the company. Mantle and the Garlands later entered into a memorandum of understanding (MOU) providing that Mantle and his wife would buy the company, but Mantle backed out of the deal. The Garlands liquidated the company, and this litigation followed. The district court disposed of some claims on summary judgment and resolved the remainder after a bench trial. The Supreme Court affirmed, holding (1) the Garlands and their entities did not abandon their counterclaims; (2) the MOU was an enforceable contract; (3) the district court correctly dismissed the Mantles’ fraud claim; (4) the district court correctly concluded that some conveyances by the Garlands fit the definitions of a fraudulent conveyance; (5) the elements for LLC veil-piercing were absent; and (6) the Garlands did not owe Mantle a duty of good faith. View "Garland v. Mantle" on Justia Law

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The Supreme Court affirmed the judgment of the district court in favor of Sellers in this case involving a purchase of residential property, holding that the district court did not err in the proceedings below. After Buyers purchased residential property from Sellers, Buyers alleged that Sellers failed to comply with the requirement in the purchase contract that “Seller…complete a fully functional water well prior to closing” and thus breached the contract. The district court entered judgment in favor of Sellers. The Supreme Court affirmed, holding that the district court (1) did not err in ruling that Sellers completed a functional well by closing and thus did not breach the purchase contract; and (2) did not commit reversible error by excluding particular testimony or exhibits offered by Buyers. View "Schell v. Scallon" on Justia Law

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The Supreme Court affirmed the jury verdict awarding Basic Properties, Inc. $200,000 in damages for Essex Holding, LLC’s refusal to consent to amend restrictive covenants to allow Basic to develop one of its lots in a shopping center. The Court held (1) Essex timely filed its notice of appeal; (2) Basic had standing to assert its counterclaim; (3) the district court did not err when its submitted Basic’a counterclaim for breach of contract to the jury; (4) the jury instructions rejecting Essex’s theory regarding a void amendment did not constitute plain error; (5) cumulative error did not result in an excess verdict or a verdict contrary to law; (6) the district court properly granted basic’s motion for judgment as a matter of law on Essex’s anticipatory repudiation claim; (7) the district court did not err in its award of attorney fees and costs to Basic; and (8) the district court properly denied Essex’s Wyo. R. Civ. P. 60(b) motion. View "Essex Holding, LLC v. Basic Properties, Inc." on Justia Law

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The Supreme Court affirmed the district court’s order granting summary judgment in favor of Taco John’s International, Inc. (TJI), concluding that TJI properly terminated Plaintiffs, two corporate executives, for violating their employment agreements. Plaintiffs brought this action asserting breach of the employment agreements and seeking damages in excess of $1 million each. The district court granted summary judgment for TJI. The Supreme Court affirmed, holding (1) the undisputed facts showed that Plaintiffs breached the employment agreements by forming a new company while still employed as senior executives at TJI and pursuing a franchise opportunity unrelated to TJI; (2) the employment agreements unambiguously prohibited Plaintiffs from forming a new company and seeking other franchise opportunities while employed by TJI, and therefore, TJI properly terminated Plaintiffs’ employment for cause; and (3) TJI’s president and chief executive officer did not have apparent authority to allow Plaintiffs’ participation in a business venture unrelated to TJI and contrary to the terms of their employment agreements. View "Eby v. Taco John's International, Inc." on Justia Law