Justia Wyoming Supreme Court Opinion Summaries

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

In 2020, Wagonhound Land & Livestock, LLC purchased the 14,000-acre Tomahawk Ranch in Converse County, Wyoming. Shortly after, Wagonhound filed an action to quiet title to approximately forty acres that Boot Ranch, LLC had occupied and used since at least 1984. Boot Ranch counterclaimed for adverse possession of the property. The district court found that Boot Ranch had made a prima facie showing of adverse possession but concluded that Wagonhound had rebutted this claim by proving the existence of a fence of convenience and neighborly accommodation, thus quieting title in Wagonhound’s favor.The District Court of Converse County held a four-day bench trial and found that Boot Ranch had continuously used the disputed property for grazing, recreation, hunting, and fishing since at least 1984. However, the court concluded that the fence partially enclosing the property was a fence of convenience and that the use of the property was a result of neighborly accommodation. Consequently, the court ruled that Boot Ranch’s use was permissive, defeating its adverse possession claim. Boot Ranch appealed the decision.The Supreme Court of Wyoming reviewed the case and found that the evidence did not support the district court’s findings that the fence was one of convenience or that the use of the property was a neighborly accommodation. The court noted that there was no evidence of a convenience served by the fence and that the actions of removing trespassing cattle indicated assertions of exclusive ownership rather than permissive use. The Supreme Court of Wyoming reversed the district court’s decision and remanded the case for entry of an order quieting title to the disputed property in favor of Boot Ranch. View "Boot Ranch, LLC v. Wagonhound Land & Livestock Co., LLC" on Justia Law

The Wyoming Board of Land Commissioners (Board) manages state trust lands for the benefit of public schools. In Teton County, the Board issued temporary use permits to Basecamp Hospitality, LLC and Wilson Investments, LLC for commercial activities on state trust lands. Teton County challenged these permits, arguing they should be subject to local land use regulations. The district court dismissed Teton County's challenge, stating the county lacked standing for judicial review. Subsequently, Teton County issued abatement notices to the permit holders, which led the Board to seek declaratory and injunctive relief, claiming sovereign immunity from local regulations.The Teton County Board of County Commissioners (Teton County) filed a petition for review, which was dismissed by the Ninth Judicial District Court. The Board then filed for declaratory judgment and injunctive relief in the First Judicial District, Laramie County, Wyoming. The district court issued a temporary restraining order and preliminary injunction against Teton County's enforcement actions. Citizens for Responsible Use of State Lands (CRUSL), formed by local property owners, sought to intervene, claiming their interests were directly impacted by the use of the state trust lands.The Wyoming Supreme Court reviewed the case. CRUSL argued it had a significant protectable interest due to the proximity of its members' properties to the state trust lands. However, the court found CRUSL's interests were contingent on the outcome of the sovereign immunity issue and thus not significant protectable interests. Additionally, the court held that Teton County adequately represented CRUSL's interests, as both sought to enforce local regulations on state trust lands. Consequently, the court affirmed the district court's denial of CRUSL's motion to intervene as a matter of right under Wyoming Rule of Civil Procedure 24(a)(2). View "Citizens for Responsible Use of State Lands v. State" on Justia Law

Stage Stop, Inc. purchased a lot in the Rafter J Ranch Subdivision in Teton County, Wyoming, intending to convert an existing building into workforce housing apartments. The Rafter J Ranch Homeowner’s Association (HOA) sought a declaratory judgment that this proposed use violated the subdivision’s covenants, conditions, and restrictions (CCRs). The district court granted summary judgment in favor of Stage Stop, determining that the proposed use was permitted under the CCRs, and the HOA appealed.The district court found that the CCRs allowed for "any commercial purpose" on Lot 333, which included Stage Stop’s proposed use of the building for workforce housing. The court reasoned that renting out apartments as a for-profit enterprise fell within the definition of a commercial purpose. The HOA argued that the CCRs, when read as a whole, intended to maintain the residential character of the subdivision and that the proposed use was inconsistent with this intent. The HOA also contended that Stage Stop should be judicially estopped from asserting that the CCRs permitted the proposed use because Stage Stop had previously indicated it would seek to amend the CCRs.The Wyoming Supreme Court affirmed the district court’s decision. The court held that the term "commercial" in the CCRs was clear and unambiguous and included the proposed use of the property for workforce housing. The court rejected the HOA’s argument that the CCRs, when read in their entirety, prohibited the proposed use, noting that the CCRs expressly allowed for "any commercial purpose" on Lot 333. The court also found that the Master Plan referenced by the HOA was inadmissible extrinsic evidence and that the argument related to the "local commercial" designation in the Plat Notes was not properly raised before the district court. Finally, the court concluded that judicial estoppel did not apply because the statements made by Stage Stop in a letter to the County Commissioners were not judicial declarations and did not involve the same issues or parties as the current case. View "Rafter J Ranch Homeowner's Association v. Stage Stop, Inc." on Justia Law

Casey and Janae Ruppert entered into a contract to purchase ranch property from Judith Merrill. Before closing, Merrill indicated she would not proceed with the sale. The Rupperts filed a complaint seeking specific performance and damages. The district court found Merrill breached the contract and denied her affirmative defenses. It awarded the Rupperts damages and attorneys’ fees but declined to order specific performance. The Rupperts appealed the denial of specific performance, and Merrill cross-appealed the attorneys’ fees award.The District Court of Laramie County found Merrill breached the contract but declined to order specific performance, citing Merrill’s personal circumstances and misunderstandings about the contract. It awarded the Rupperts $22,342 in damages and granted their motion for attorneys’ fees without explanation, awarding $55,258.50 in fees and $3,082.60 in costs.The Wyoming Supreme Court reviewed the case and found the district court abused its discretion by denying specific performance. The court noted the district court’s findings contradicted its decision, as it found the contract valid, the price reasonable, and no undue influence or unconscionability. The Supreme Court held that specific performance was the appropriate remedy given the circumstances and the equities involved.Regarding attorneys’ fees, the Supreme Court agreed with both parties that the district court erred by awarding fees without explanation. The Supreme Court independently assessed the reasonableness of the fees, concluding that the rates charged were excessive for the local market. It reduced the hourly rate to $250, resulting in a total fee award of $28,425.00, plus the previously awarded costs of $3,082.60.The Wyoming Supreme Court reversed the district court’s orders denying specific performance and awarding attorneys’ fees, remanding the case for entry of an order consistent with its opinion. View "Merrill v. Ruppert" on Justia Law

Phoenix Capital Group Holdings, LLC (Phoenix Capital) sought to recover mineral royalties as a life tenant and alternatively to reform the deed that established its life estate. The dispute arose from a series of property transfers beginning in 1977, when Mr. and Mrs. Peterson transferred a parcel of real property to Alva and Velma Woods, retaining a life estate in the mineral estate. In 2003, Alva and Velma deeded the property to their son Paul and his wife Cheryl, intending to retain a life estate in the mineral estate. However, the 2003 deed did not reserve this life estate, leading to a 2006 deed that conveyed a life estate in one-half of the mineral estate to Alva and Velma. Subsequent leases were executed, and in 2021, Velma sold her life estate to Phoenix Capital.The District Court of Laramie County dismissed Phoenix Capital’s claims. It concluded that under the doctrine of waste, a life tenant does not have the right to receive royalties unless expressly stated in the deed or agreed upon with the remainderman. The court also found that the claim to reform the deed was barred by the statute of limitations, which began when the deed was recorded in 2006.The Wyoming Supreme Court reviewed the case and affirmed the lower court’s decisions. The court held that the doctrine of waste precludes a life tenant from receiving royalties without an agreement with the remainderman or express language in the deed. The court also held that the statute of limitations for reformation claims begins when the deed is recorded, making Phoenix Capital’s 2022 reformation claim untimely. The court found no error in the district court’s application of settled law and affirmed the dismissal of Phoenix Capital’s claims. View "Phoenix Capital Group Holdings, LLC v. Woods" on Justia Law

A group of property owners and entities challenged the Albany County Board of County Commissioners' amendments to zoning regulations known as the Aquifer Protection Overlay Zone (APOZ). The amendments aimed to protect the Casper Aquifer, which supplies drinking water to many residents in Albany County, including those in the City of Laramie. The property owners argued that the Board's adoption of the amendments was arbitrary, capricious, and exceeded its authority.The District Court of Albany County dismissed the petitions for review, concluding that it lacked jurisdiction because the amendments were legislative acts and not reviewable under the Wyoming Administrative Procedure Act (WAPA). The property owners and entities appealed, arguing that the Board's actions were reviewable and that the Board lacked the authority to adopt the amendments.The Wyoming Supreme Court reviewed the case and clarified that there is no common law or general statutory exception to judicial review of agency legislative actions. The court held that the characterization of the Board’s action as legislative or adjudicatory dictates the scope and nature of the review. The court concluded that the district court has jurisdiction to review the APOZ amendments and remanded the case to the district court to conduct an analysis in conformance with the opinion. The court emphasized that judicial review of agency legislative actions is limited by the separation of powers doctrine and should focus on whether the actions were contrary to constitutional rights, not in accordance with the law, in excess of statutory authority, or divergent from the agency's own rules. View "Warren Livestock, LLC v. Board of County Commissions" on Justia Law

In 2014, a woman and her two children from a previous relationship moved in with a man. They had a child together in 2018 and married in 2019. The man ran a trucking business, and the woman assisted with bookkeeping. She also worked briefly at a mental health facility and later as a secretary at a hospital. The couple separated in March 2022, and the woman filed for divorce shortly thereafter.The District Court of Weston County entered a stipulated decree of divorce in January 2023, settling child custody, visitation, and child support. However, the division of marital property was disputed. A bench trial was held in April, and the court issued its final order in November, dividing the marital property. The court considered the equitable value of the marital home, rental property, livestock, personal vehicles, personal property, and debts. The man was assigned the marital home, while the woman received her retirement funds and an equalization payment from the man.The man appealed to the Supreme Court of Wyoming, arguing that the district court abused its discretion in dividing the marital property. He contended that the court failed to allocate a portion of an IRS debt to the woman and improperly valued his trucking business. The Supreme Court reviewed the district court’s findings for an abuse of discretion and found no clear error. The court noted that the district court had appropriately considered the statutory factors under Wyo. Stat. Ann. § 20-2-114(a) and had made a just and equitable division of the property.The Supreme Court of Wyoming affirmed the district court’s decision, concluding that the property division was not so unfair and inequitable that reasonable people could not abide by it. The court also found that the district court had reasonably considered each of the statutory factors and that its ruling did not shock the conscience. View "Regan v. Regan" on Justia Law

Donald and Mary Fuger own forty acres of land in Wyoming. Larry Wagoner began using a five-acre section of this land for his oilfield business around 2008. The Fugers and Wagoner agreed to construct two buildings on the site, with Wagoner handling construction and the Fugers securing financing. They did not formalize this agreement in writing. A lease agreement was signed, giving Wagoner exclusive use of the buildings for five years. Wagoner claimed there was an oral agreement to transfer ownership of one building and the land to him in exchange for his construction work and loan payments, which the Fugers denied.The District Court of Sweetwater County initially found in favor of Wagoner, awarding him damages for breach of the oral contract. However, the Wyoming Supreme Court reversed this decision in Fuger v. Wagoner, 2020 WY 154, ruling the oral contract void because Mrs. Fuger did not join the agreement. The case was remanded to consider Wagoner’s equitable claims. On remand, the district court found the Fugers were unjustly enriched by Wagoner’s construction work and awarded him damages, offsetting some of these due to his use of the buildings. The court also awarded prejudgment interest on a portion of the damages.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 offsetting Wagoner’s damages by the actual rent he received rather than the fair rental value of the second building. The court also upheld the award of prejudgment interest, finding that a portion of Wagoner’s damages were liquidated and thus subject to such interest. The court concluded that the district court acted within its discretion in its equitable determinations regarding offset and prejudgment interest. View "Fuger v. Wagoner" on Justia Law

This case involves a dispute over a parcel of land between two neighboring property owners in Park County, Wyoming. The appellants, Michael and Michelle Sellers, purchased a 12-acre property that was adjacent to a 4-acre parcel owned by the appellees, Phyllis Claudson, William Pond, Pamela Pond, and Peggy Lou Pond Paul. During the purchase, the Sellers discovered that a portion of their property was located on the Ponds' side of a boundary fence. The Ponds filed a lawsuit to claim ownership of this portion of land based on adverse possession.The District Court of Park County initially heard the case. The Ponds and the Sellers filed cross-motions for summary judgment. The district court ruled in favor of the Ponds, finding that they had adversely possessed the disputed property. The Sellers appealed this decision.The Supreme Court of Wyoming reviewed the case and affirmed the lower court's decision. The court found that the Ponds had established a prima facie case for adverse possession. They had shown actual, open, notorious, exclusive, and continuous possession of the disputed property, which was hostile and under claim of right or color of title. The Sellers failed to rebut this claim by showing permissive use of the property through neighborly accommodation. The court also rejected the Sellers' argument that the Ponds could only have adversely possessed the areas of the property containing buildings, as the Sellers had not raised this issue in the lower court. View "Sellers v. Claudson" on Justia Law