Justia Wyoming Supreme Court Opinion Summaries

Jackson Hole Hereford Ranch, LLC (JHHR) sought to partition real property it claimed to own as a tenant in common with Leeks Canyon Ranch, LLC (Leeks). Leeks counterclaimed, asserting sole ownership based on judicial estoppel, equitable estoppel, and adverse possession. The district court granted partial summary judgment to JHHR, dismissing Leeks’s judicial and equitable estoppel claims. After a bench trial, the court ruled against Leeks on the adverse possession claim. Leeks appealed both the summary judgment and the trial findings.The District Court of Teton County granted summary judgment to JHHR on Leeks’s judicial and equitable estoppel claims. The court found that Mr. Gill, representing JHHR, had forgotten about his 25% interest in the property during arbitration, negating the application of judicial estoppel. The court also found no evidence of willful misconduct or serious negligence by Mr. Gill, which is necessary for equitable estoppel. The court held that Mr. Gill’s statements during arbitration were not sufficient to establish estoppel.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The Supreme Court agreed that judicial estoppel did not apply because Mr. Gill’s prior position was based on a mistake. The court also upheld the summary judgment on equitable estoppel, finding no evidence of willful misconduct or serious negligence by Mr. Gill. Regarding adverse possession, the Supreme Court found that Leeks failed to prove that its possession of the property was hostile to JHHR’s interest. The court noted that Leeks did not provide clear notice to JHHR that its ownership was in jeopardy, a requirement for adverse possession among cotenants. The Supreme Court affirmed the district court’s rulings in favor of JHHR. View "Leeks Canyon Ranch, LLC v. Jackson Hole Hereford Ranch, LLC" 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

Samuel Tilden filed a complaint against his neighbor, Linda Jackson, seeking a declaration of an implied easement over Jackson’s property or, alternatively, the establishment of a private road under Wyoming Statute § 24-9-101. Tilden had sold a portion of his property to Jackson in 2010 but retained a 2.64-acre parcel (Subject Property) that included a steep hillside and a flat meadow along the Southfork of the Shoshone River. Tilden and his family had historically accessed the lower portion of the Subject Property via a two-track road on Jackson’s property. After moving out of a cabin he rented from Jackson, Tilden sought legal access to the lower portion of his property.The District Court of Park County granted summary judgment in favor of Jackson on Tilden’s claim to establish a private road, finding that Tilden’s property was not landlocked as it had access to a county road. Following a bench trial, the district court also denied Tilden’s claim for an implied easement, concluding that Tilden’s use of the contested easement was not apparent, obvious, and continuous at the time of severance, and that the easement was not necessary for the enjoyment of his property.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not err in granting summary judgment on the private road claim because Tilden’s property had legally enforceable access to a public road, and the necessity for a private road was not established. Additionally, the court upheld the denial of the implied easement, agreeing with the district court’s findings that Tilden’s use of the proposed easement was not apparent, obvious, and continuous at the time of severance, and that the easement was not necessary for the enjoyment of his property. The court emphasized that implied easements should only be recognized when strictly necessary for the use and enjoyment of the dominant estate. View "Tilden v. Jackson" on Justia Law

The State of Wyoming, Board of Land Commissioners (State Board), granted Temporary Use Permits (TUPs) to permittees for the use of state land in Teton County. The Teton County Board of County Commissioners (County Board) issued abatement notices to the permittees, asserting violations of county land use regulations. The State Board sought a declaration that it and its permittees were not subject to these regulations. The district court granted summary judgment in favor of the State Board, and the County Board appealed.The district court found that the State Board and its permittees were not subject to Teton County's land use and development regulations. The County Board argued that Wyoming statutes required compliance with local zoning laws for state lands under long-term leases and TUPs. The State Board countered that sovereign immunity protected it from such regulations and that the statutes did not apply to TUPs.The Wyoming Supreme Court reviewed the case de novo and affirmed the district court's decision. The court held that the State Board and its permittees operating under a TUP are not subject to county land use and development regulations. The court reasoned that while Wyoming statutes require compliance with local zoning laws for long-term leases of state lands, they do not impose the same requirement for TUPs. The court emphasized that the legislature's omission of TUPs from the statutory requirement for compliance with local zoning laws was intentional. Therefore, the County Board lacked the authority to enforce its land use regulations against the State Board and its permittees operating under a TUP. View "Teton County Board of County Commissioners v. State" on Justia Law

The Randy W. Stevens Living Trust owns land in Saratoga, Wyoming, bordered by an alleyway owned by the Town of Saratoga. Randy Stevens, the trustee, and Quality Landscape & Nursery, Inc., which uses the land, have had various disputes with the Town over the years. In 2019, a judgment was issued in favor of the Town, which the Stevens parties did not appeal. In 2023, the Stevens Trust and Quality Landscape filed a motion for an order to show cause and for a writ of mandamus, which the district court dismissed, citing res judicata and the parties' contractual limitations period. The court also found mandamus was not available under the circumstances.The district court of Carbon County had previously ruled on several issues between the parties, including the reconstruction of the alleyway, installation of utilities, and access to the property. The court found that the Town had acted in good faith and that the Stevens parties had failed to prove damages. The Stevens parties did not appeal these rulings. In 2023, they sought to revisit these issues, but the district court dismissed their motion, finding that the claims were barred by res judicata and the contractual limitations period.The Supreme Court of Wyoming reviewed the case and affirmed the district court's decision. The court held that the claims raised by the Stevens parties were barred by res judicata, as they had been or could have been litigated in prior proceedings. The court also agreed that mandamus was not an appropriate remedy, as the duties in question were not ministerial. Finally, the court found that judicial estoppel did not apply, as the Town had not taken inconsistent positions. The court affirmed the district court's dismissal of the Stevens parties' motion. View "Stevens v. The Governing Body of the Town of Saratoga, Wyoming" on Justia Law

Harold Sheppard, Jr., who operates a plane salvage and trucking business, began leasing part of the South Big Horn County Airport in 2011 for a metal scrapping and recycling venture. In 2019, Big Horn County sued him for unpaid rent, resulting in a money judgment and an order to remove his property, which he did not comply with. In 2021, the County filed a $543,600 storage lien against his property. Sheppard then sued the Board of County Commissioners to stop the sale of his property, challenge the lien, and seek damages. The parties engaged in settlement negotiations in September 2022, leading to the vacating of a scheduled trial.The County Commissioners moved to dismiss Sheppard’s claims for failure to prosecute in January 2024, citing a lack of action since the September 2022 status conference. The district court granted the motion, dismissing the case with prejudice. Sheppard did not appeal this dismissal but filed a motion to reconsider under W.R.C.P. 60(b)(6) in March 2024, arguing that the dismissal was premature and that the court should enforce the settlement agreement before dismissing the case.The district court denied Sheppard’s motion, finding he failed to meet the burden for relief under Rule 60(b)(6). Sheppard appealed, arguing that the district court abused its discretion by not recognizing the unusual circumstances and the existence of a settlement agreement. The Wyoming Supreme Court reviewed the case and found that the district court did not abuse its discretion. The court noted that Sheppard failed to protect his legal interests by ensuring the settlement agreement and lease were executed and that his delay in filing the motion to reconsider was unreasonable. The Supreme Court affirmed the district court’s decision. View "Sheppard v. Board of County Commissioners, In and for Big Horn County, Wyoming" on Justia Law

In 2021, Contango Resources, LLC purchased oil and gas production and processing facilities in Fremont and Sweetwater Counties, Wyoming. In 2022, the Fremont County Assessor assessed the taxable value of the property located in Fremont County. Contango appealed the assessment to the Fremont County Board of Equalization, arguing that the County Assessor and her expert consultant failed to properly use the purchase price of the property in their valuations and used improper trending and depreciation factors. The County Board upheld the valuation.The State Board of Equalization and the district court both affirmed the County Board's decision. Contango then appealed to the Wyoming Supreme Court. The main issues on appeal were whether the County Board’s decision to uphold the County Assessor’s rejection of the property’s purchase price as a starting point for valuation was supported by substantial evidence and in accordance with law, and whether the County Board’s decision to uphold the County Assessor’s application of trending and depreciation factors in the valuation was in accordance with law.The Wyoming Supreme Court affirmed the lower court's decision. The Court held that the County Assessor was justified in rejecting the purchase price as a starting point for valuation due to the lack of detailed information and the complexity of the Purchase and Sale Agreement (PSA). The Court also found that the Assessor’s use of trending and depreciation factors outside those recommended by the Department of Revenue was permissible under the Department’s rules, as long as the sources were credible. The Court concluded that the County Board’s rulings were supported by substantial evidence and in accordance with law. View "Contango Resources, LLC v. Fremont County" on Justia Law

The case involves a dispute between homeowners in the Dairy Subdivision in Teton County, Wyoming. The appellants, Robert, Linda, and Anthony Schroth, along with Jackson Hole Winery, LLC, were enjoined by the district court from conducting certain commercial activities on their property, which the appellees, Robert and Viesia Kirk, claimed violated the subdivision's covenants. The covenants restrict the use of properties to single-family residential purposes and prohibit commercial activities, although they allow for certain home occupations and agricultural activities.The district court found that the activities of Jackson Hole Winery, which included wine production, sales, and hosting public tastings, were commercial and violated the covenants. The court also found that the appellants' claims of laches, arguing that the Kirks delayed unreasonably in enforcing their rights, were unfounded. The court issued a permanent injunction limiting the winery's activities to those initially approved by the subdivision's design committee in 2010.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The Supreme Court agreed that the winery's expanded activities were commercial and violated the covenants. The court also upheld the district court's finding that the Kirks did not delay unreasonably in enforcing their rights, noting that the Kirks only became aware of the full extent of the winery's activities in 2020 and filed suit in 2022. The court found no abuse of discretion in the district court's decision to grant the injunction, as the equities weighed in favor of enforcing the covenants to preserve the residential character of the subdivision. View "Schroth v. Kirk" on Justia Law

In August 2021, Sean Halling applied for a variance from the Town of Afton to build an accessory building larger than the 900 square feet allowed by the local development code. The variance was approved by the Town Council in September 2021. In February 2022, the Zoning Administrator approved a modification to increase the building's size without public notice. The appellants, neighbors of Mr. Halling, observed the construction and became concerned about the building's size and potential use. They sent a letter to the Town in October 2022 and filed a declaratory judgment action in December 2022.The District Court of Lincoln County dismissed the appellants' action, concluding they failed to exhaust administrative remedies and that the matter was moot due to changes in the local development code allowing buildings of the size in question without a variance. The appellants appealed the decision.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court held that the appellants were required to exhaust administrative remedies specified in the Afton Land Development Code before seeking judicial intervention. The court found that the appellants did not appeal the Zoning Administrator's decision to the Town Council acting as the Board of Adjustment within the required timeframe. The court also concluded that the Town Council was acting in its capacity as the Board of Adjustment when it approved the initial variance, and the appellants failed to appeal that decision within a reasonable time. The court emphasized the importance of following prescribed administrative processes for resolving zoning disputes. View "Sorensen v. Halling" 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