Justia Wyoming Supreme Court Opinion Summaries

Amy Landerman filed a complaint against Nathan Cook alleging that Cook fraudulently obtained shares of Landerman’s company, a Wyoming corporation. The district court entered judgment against Cook, finding that Cook committed fraud in the inducement and fraud in the execution. The total damages equaled $149,189. The district court also awarded punitive damages in the form of attorney fees in the amount of $114,063. The Supreme Court affirmed in all respects, holding (1) there was sufficient evidence for the district court to find fraud in the inducement; (2) the district court did not abuse its discretion in awarding punitive damages; and (3) the district court’s finding that a contract, in the form of an oral agreement, existed was supported by the record. View "Positive Progressions, LLC v. Landerman" on Justia Law

Appellants and the company they own filed suit against David Fisher and other defendants, alleging claims arising from an unfulfilled real estate purchase agreement. Fisher filed an answer and counterclaim. Three years later, Fisher filed for Chapter 7 bankruptcy. Appellants filed an adversary proceeding in the bankruptcy case, requesting a determination that their claims against Fisher were not dischargeable in bankruptcy. The district court subsequently dismissed Appellants’ claims. Thereafter, the bankruptcy court ruled that Appellants’ claims against Fisher were dischargeable in bankruptcy. Appellants then filed a motion to modify the district court’s order dismissing the action and a renewed motion for summary judgment. The district court denied both post-dismissal motions, noting that the matter had already been dismissed. On appeal, the Supreme Court treated Appellants’ motions as motions for relief from the dismissal order pursuant to Wyo. R. Civ. P. 60(b) and affirmed, holding that, under the circumstances of this case, the district court did not abuse its discretion in denying Appellants’ motions. View "Bartel v. West" on Justia Law

Electrical Wholesale Supply Co. (EWS) filed this action seeking payment for electrical materials it supplied to a commercial building remodel. EWS sued, among other defendants, Alane Fraser, the owner of the commercial property, and M.J. Bishop Concrete & Construction, Inc. (Bishop Construction), the general contractor, for foreclosure of a construction lien, breach of contract, unjust enrichment, and third party beneficiary. The circuit court denied EWS’s claims. The district court affirmed. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the circuit court (1) applied the wrong statute to the lien notice issue and erred by granting summary judgment in favor of Fraser on the lien claim; but (2) did not err in concluding that EWS did not prove its unjust enrichment claim against Fraser and Bishop Construction. View "Elec. Wholesale Supply Co., Inc. v. Fraser" on Justia Law

This dispute arose from promises Defendant Daniel Ochsner allegedly made during Plaintiffs’ several-year tenure living and working on Defendants’ ranch. The district court denied all of Plaintiffs’ claims and Defendants’ counterclaims. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in denying Plaintiffs’ claims to a number of cattle; (2) erred in denying Plaintiffs’ claims to a cattle brand; (3) did not err in denying Plaintiffs’ Wyo. R. Civ. P. 15(b) motion to amend their complaint to conform to the evidence and to add promissory estoppel claims; and (4) did not err in denying Plaintiff’s motion to confirm an alleged settlement agreement between the parties. View "Gould v. Ochsner" on Justia Law

This dispute arose from promises Defendant Daniel Ochsner allegedly made during Plaintiffs’ several-year tenure living and working on Defendants’ ranch. The district court denied all of Plaintiffs’ claims and Defendants’ counterclaims. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in denying Plaintiffs’ claims to a number of cattle; (2) erred in denying Plaintiffs’ claims to a cattle brand; (3) did not err in denying Plaintiffs’ Wyo. R. Civ. P. 15(b) motion to amend their complaint to conform to the evidence and to add promissory estoppel claims; and (4) did not err in denying Plaintiff’s motion to confirm an alleged settlement agreement between the parties. View "Gould v. Ochsner" on Justia Law

Appellant submitted a bid for a highway project in Sublette County, Wyoming and was the low bidder. The Board of County Commissioners of Sublette County awarded the contract to another bidder, a contractor that was from Sublette County. Appellant filed a complaint in the district court alleging that by not entering into the contract with Appellant, the Commissioners violated Wyo. Stat. Ann. 16-6-102(a). The district court found in favor of the Commissioners on all claims. On appeal, the Supreme Court held section 16-6-102(a) inapplicable and remanded the case for a determination of whether the award was appropriate. On remand, the district court held generally in favor of the Commissioners, finding that the Commissioners’ award was within their discretion and appropriate. The Supreme Court reversed, holding that the Commissioners’ utilization of an undisclosed preference for Sublette County contractors in awarding the public contract opened for competitive bid constituted an illegal exercise of discretion. Remanded for a determination of damages. View "W. Wyo. Constr. Co., Inc. v. Bd. of County Comm’rs" on Justia Law

Buyer agreed to purchase a portion of a 2,700 acre ranch from Sellers. Sellers agreed to finance a portion of the purchase price by accepting Buyer’s promissory note. After Buyer defaulted on the promissory note, Sellers initiated foreclosure proceedings. Buyer and its successor in interest (collectively, Buyers) filed a complaint for declaratory judgment and a motion for a temporary restraining order to halt the foreclosure, asserting several causes of action. Sellers counterclaimed, asserting that Buyers breached the terms of the promissory note. The district court granted summary judgment in favor of Sellers. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in granting summary judgment in favor of Sellers with respect to Buyers’ adverse possession claim and with respect to Sellers’ breach of contract claim; and (2) erred in denying Sellers’ request for attorney’s fees. Remanded. View "Flynn v. Ruby River Canyon Ranch, Ltd." on Justia Law

The parties in this case owned interests in certain oil and gas leases in Sublette County, Wyoming. In the underlying litigation, the district court granted a monetary judgment against Defendants for amounts due to Plaintiffs. Defendants paid the monetary judgment. Plaintiffs subsequently filed a motion to enforce judgment, claiming that Defendants were not properly accounting to them as required by the prior declaratory judgment and a net profits contract (NPC). After the district court issued its judgment, Defendants appealed the court’s decisions on the merits and its order requiring Defendants to pay attorney fees. The Supreme Court affirmed as revised, holding that the district court (1) properly assumed jurisdiction over the issues presented; (2) correctly interpreted its prior judgment and Defendants’ accounting responsibilities under the NPC; and (3) properly granted Plaintiffs’ request for attorney fees with one minor exception. View "Ultra Resources, Inc. v. Hartman" on Justia Law

At issue in this case was the Redland family’s dispute over ranch property that some Redland children (“Children”) claimed that their father (“Father”) agreed to place in a family trust. In the first appeal, the Supreme Court concluded that the district court erred in entering summary judgment, as questions of fact existed on the issues of whether Children’s claims against Father were barred by the statute of frauds and the statute of limitations. On remand, the district court determined that Children’s claims were not barred and ordered that the disputed property, with the exception of property on which Father resided (“residential property”), be immediately transferred to the family trust. With regard to the residential property, the court ordered that the property be transferred to the trust upon Father’s death. The Supreme Court affirmed as modified, holding that the district court (1) did not err in holding that an enforceable agreement existed that required placing the disputed property in the trust; (2) did not err in determining that the statute of limitations did not bar Children’s claims; and (3) erred in its disposition of the residential property. Remanded with directions that the residential property be immediately transferred to the family trust subject to Father’s life estate in the property. View "Redland v. Redland" on Justia Law

Christopher Walton and Tammara Duhn hired Jacob Hatch and his construction company (collectively, Hatch) as the general contractor to build a custom home in a subdivision. Hatch drew up two proposed written contracts, but Walton and Duhn would not sign either one. Nevertheless, construction began. A dispute over what Walton and Duhn owed Hatch led Hatch to terminate his involvement in the project before the house was finished. Walton and Duhn sued Hatch for breach of contract, among other claims. The district court entered judgment in favor of Walton and Duhn and awarded damages. The Supreme Court reversed in part and affirmed in part, holding that the district court (1) erred in calculating the damages that Walton and Duhn suffered as a result of Hatch’s improper billing practices; (2) erred in finding liability and awarding damages for breach of an implied warranty that the home would be built in a skillful and workmanlike manner; and (3) did not abuse its discretion in denying Walton’s and Duhn’s application for attorney fees. View "Walton v. Hatch" on Justia Law