Justia Wyoming Supreme Court Opinion Summaries

Western Ecosystems Technology, Inc. (Western) and GreenHunter Wind Energy, LLC entered into a contract whereby Western provided the LLC consulting services. When the LLC paid nothing for Western’s services, Western brought a breach of contract action against the LLC. Western obtained a judgment against the LLC. Because the LLC had no assets upon which Western could execute, Western brought this action against GreenHunter Energy, Inc. (Appellant), the sole member of the LLC, seeking to pierce the LLC’s veil and hold Appellant liable for the LLC’s contractual obligations. The district court found in favor of Western, pierced the LLC’s veil, and awarded a judgment of $45,807 against Appellant. The Supreme Court affirmed the district court’s judgment piercing the LLC’s veil and imposing liability on Appellant for its debt to Western, holding that the district court correctly applied the applicable law and that its findings of fact were not clearly erroneous. View "Greenhunter Energy, Inc. v. W. Ecosystems Tech., Inc." on Justia Law

Plaintiff-corporation brought a breach of contract action against Defendant-corporation. Defendant counterclaimed for breach of contract and breach of the covenant of good faith and fair dealing. A jury found that Plaintiff had breached the contract but awarded Defendant no damages. Plaintiff appealed. The Supreme Court affirmed, holding (1) the district court did not err in giving a breach of contract instruction or a challenged verdict form to the jury; and (2) the district court correctly exercised its discretion when its excluded Plaintiff’s expert testimony and reports and evidence involving a separate transaction between the parties.View "Black Diamond Energy, Inc. v. Encana Oil and Gas (USA) Inc." on Justia Law

In February 2011, two years and four months after Plaintiff learned she had been disinherited by her mother, Plaintiff filed a complaint against financial advisor Bradley Lott for fraud and constructive fraud. A jury found that Lott had committed constructive fraud but that Plaintiff knew or should have known before February 2007 that the fraud occurred. Based on the jury’s findings, the district court dismissed the action, concluding that Plaintiff’s claims were barred by the statute of limitations. The Supreme Court reversed the judgment, holding (1) the evidence did not support a finding that Plaintiff could have discovered the fraud sooner, and (2) therefore, the district court erred by dismissing the case based on the statute of limitations. Remanded for a new trial.View "Erdelyi v. Lott" on Justia Law

In 1997, the Courtenay C. Davis Foundation and Amy Davis (together, “Davis Interests”) entered into an agreement with the University of Wyoming Foundation and the Colorado State University Research Foundation (together, “University Foundations”) in which the Davis Interests donated land and other interests to the University Foundations subject to the terms of the agreement. In 2011, the University Foundations decided to sell the gifted property and listed it for sale. In 2012, the Davis Interests filed an action against the University Foundations seeking to enjoin the sale of the property. The district court dismissed the complaint for lack of standing. The Supreme Court affirmed, holding that the district court did not err in concluding that the donation from the Davis Interests to the University Foundations was a gift, that the agreement did not create an implied trust, and that only the attorney general had standing to enforce the terms of a charitable gift.View "Courtenay C. & Lucy Patten Davis Found. v. Colo. State Univ. Research Found." on Justia Law

Forsberg Engerman Co., an insurance agency, helped Lewis Holding Co., a trucking business, purchase insurance from Lexington Insurance Co. In 2011, one of Lewis Holding’s trailers was damaged. After Lewis Holding filed an insurance claim, NTA, Inc.’s adjuster examined the trailer and determined that the damage was due to mechanical failure or wear and tear. Lexington denied the insurance claim on the grounds that the damages were not the result of an upset or collision, but rather, the result of improper welding. Lewis Holding subsequently filed suit against Lexington, NTA, and Forsberg. The district court granted summary judgment for Defendants. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment for Defendants where (1) the insurance agreement plainly and unambiguously excluded coverage for damages due to mechanical failure; (2) Forsberg, who was not a party to the insurance contract, could not be held liable under the insurance policy; and (3) Defendants had reasonable bases for denying Lewis Holding’s claim.View "Lewis Holding Co., Inc. v. Forsberg Engerman Co." on Justia Law

Dan C. Morton successfully bid on several federal oil and gas leases. Morton sought the assistance of RDG Oil and Gas, LLC to develop the leases. In 2005, the parties entered into two separate agreements for the development of the leases. In 2012, Morton’s successor in interest, the Jayne Morton Living Trust, filed a complaint against RDG alleging breach of contract of both agreements. RDG did not respond to the complaint, and the district court entered a default judgment against RDG. RDG later moved to set aside the entry of default and the default judgment. The district court denied RDG’s motions. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying RDG’s motion to set aside the entry of default and the entry of default judgment. View "RDG Oil & Gas, LLC v. Jayne Morton Living Trust " on Justia Law

The Andrews, a married couple, contracted to purchase a newly constructed home from Appellants, Joe Seneshale and his company, Legacy Builders, LLC (together, Legacy). After the Andrews took possession of the property, they discovered that the house had numerous structural and cosmetic flaws. The Andrews filed a complaint against Legacy alleging breach of contract and breach of implied warranty of habitability. The trial court entered judgment in favor of the Andrews and awarded a total of $319,302 in damages. The Supreme Court affirmed but remanded with instructions to correct the damage award, holding (1) when the cost of repairs in a homeowners’ construction case alleging breach of contract and breach of warranty may be disproportionate to the loss in value to the home resulting from the breach, the plaintiff has the burden of proving damages at trial, and the defendant has the burden of challenging the reasonableness or disproportionality of the plaintiff’s method; and (2) the district court did not commit clear error when it relied upon the majority of the Andrews’ cost of repair expert’s testimony and when it found that expansive soils caused damages to the home’s foundation. View "Legacy Builders, LLC v. Andrews" on Justia Law

At issue in this case was a joint operating agreement (JOA) for Wyoming oil and gas interests entered into in 2000 by the predecessors in interest to Windsor Energy Group, LLC and Windsor Beaver Creek, LLC (together, Windsor) and Noble Energy, Inc. (Noble). In 2004, Noble’s predecessor assigned its interest to another party. In 2010, Windsor filed suit against Noble’s predecessor, claiming it was obligated for costs under the JOA. The district court ruled (1) an assignor of an interest who was not formally released was still obligated under the JOA, but (2) Windsor’s claim against Noble for breach of the JOA was barred by laches. The Supreme Court affirmed the district court’s judgment without addressing the contract issue, holding that the district court (1) did not err in ruling that the equitable doctrine of laches was an available defense to Windsor’s claim for breach of the JOA even though the statute of limitations had not expired; and (2) did not abuse its discretion by finding the elements of laches were satisfied in this case. View "Windsor Energy Group, LLC v. Noble Energy, Inc." on Justia Law

Defendant, a contractor, and Plaintiff, a subcontractor, entered into a two subcontracts for part of a road work project. Plaintiff invoiced Defendant for the work under both contracts, but when Defendant failed to pay the full amount, Plaintiff filed suit for breach of contract damages and storage fees for Defendant’s equipment and materials. Defendant counterclaimed, alleging that Plaintiff had been overpaid on the contracts and had converted Defendant’s equipment. Defendant moved to have the matter removed to federal court and filed its counterclaim in that court. The case was subsequently remanded to state court, where Defendant filed its counterclaim. Plaintiff moved for summary judgment, claiming Defendant’s counterclaim was untimely. The district court granted the motion and dismissed the counterclaim. After a bench trial, judgment was entered in favor of Plaintiff. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate any basis to reverse the district court’s dismissal of its counterclaim on summary judgment; (2) alternatively, Defendant’s proposed counterclaim was moot; and (3) Plaintiff was entitled to attorney fees and costs. View "Motzko Co. USA, LLC v. A & D Oilfield Dozers, Inc." on Justia Law

Appellants decided to sell 850 acres of farmland but wanted to retain the mineral rights. Summit Title Services prepared the deeds for the sale, but he deeds did not reserve the minerals. Appellants were made aware of the omission at closing, insisted that the deeds be corrected, and were assured by Summit’s employee that the problem had been rectified. Six years later, Appellants learned that the minerals had been transferred with the land. Appellants filed suit against Summit, its general counsel Olen Snider, and Kuzma Success Realty, a brokerage firm involved in the transaction. The district court granted summary judgment for Appellees on all claims, concluding that Appellants failed to exercise due diligence to discover the error so as to extend the statute of limitation as a matter of law. The Supreme Court reversed the grant of summary judgment to Summit and Snider, concluding that there were genuine issues of material fact as to whether Appellants exercised due diligence to discover errors allegedly made by Summit and that Snider failed to present a prima facie case that he was entitled to summary judgment. View "Moats v. Prof'l Assistance, LLC " on Justia Law