Justia Wyoming Supreme Court Opinion Summaries

A landowner sought to establish a private road across a neighboring ranch property to access an isolated parcel it owns, which is largely surrounded by the neighbor’s land. The landowner made unsuccessful attempts to negotiate an easement, then filed a petition under Wyoming’s private road statute to secure access. The parcel in question lacks legally enforceable vehicle access except through the neighbor’s land. Various options for routes, including one passing through public land, were considered, but physical and legal barriers precluded public access.The District Court of Albany County held a bench trial, appointed viewers and appraisers to review potential routes, and ultimately established a private road along the landowner’s proposed route, finding it to be the most reasonable and convenient. The court awarded damages to the neighbor based on a “before and after” appraisal, and imposed several conditions on the private road. The landowner appealed three of those conditions, while the neighbor cross-appealed, challenging the findings of good faith, necessity, route selection, damages, and denial of an agricultural-use-only restriction.The Supreme Court of Wyoming affirmed the district court’s findings of good faith, necessity, route selection, and damages, as well as its rejection of the agricultural-use-only restriction. The court concluded that the parcel was landlocked and that neither the purported public land route nor alternative bypasses provided legally enforceable access. It found the chosen route was most reasonable and convenient and that damages were properly calculated. However, the Supreme Court reversed two conditions imposed by the district court—specifically, the requirement that the landowner repair any damage regardless of fault, and the restriction on vehicles with more than four axles—because they were not supported by evidence. The remaining challenged condition and the denial of the agricultural-use-only restriction were affirmed. View "Wagonhound Land & Livestock Company, LLC v. Little Medicine Creek Ranch, Inc." on Justia Law

The appellant owns a one-story home in Laramie County, Wyoming. In April 2024, the Laramie County Assessor valued her property at $188,822. After the appellant objected, field appraisers inspected the home, which led to a series of adjustments, ultimately lowering the valuation to $164,939. Throughout these valuations, the home’s condition was rated as “average” and its quality as “low.” The appellant contended that her home’s value should be reduced further, citing its age, lack of updates, limited livable space, and certain deficiencies such as a non-livable basement and outdated construction features.Following an appeal by the appellant, the Laramie County Board of Equalization held a contested hearing. The appellant presented evidence including her home’s purchase price, its physical shortcomings, and comparisons to other neighborhood homes. The Board heard testimony from the Assessor regarding the process for property valuation and the guidelines for assigning condition ratings. Despite the field appraisers’ assessment, the County Board, by a 3-2 vote, determined that the condition should be downgraded from “average” to “fair” and remanded the matter to the Assessor for reclassification. The Board based its decision on limited photographic evidence and the appellant’s testimony.The Assessor appealed to the Wyoming State Board of Equalization, which reversed the County Board’s decision, finding it was not supported by substantial evidence. The district court affirmed the State Board. On further appeal, the Supreme Court of Wyoming reviewed only the County Board’s decision. The Supreme Court held that the County Board’s determination to downgrade the property’s condition was not supported by substantial evidence, as the appellant did not present credible evidence sufficient to rebut the presumption in favor of the Assessor’s valuation. The Supreme Court reversed the County Board’s decision. View "Gummel v. Laramie County Assessor" on Justia Law

The case concerns a dispute arising from an oral agreement between a homeowner and a contractor regarding the construction of a wheelchair ramp and a covered addition at the homeowner’s residence. The parties did not sign a written contract or agree to a specific price, instead communicating the project’s scope via text messages. The homeowner paid the contractor $73,000, including $30,000 for siding, but the project was plagued by construction delays, quality concerns, and code violations. Work ceased before completion, and the contractor did not deliver or install the siding. The homeowner and his wife continued living in the property, though it did not receive a final certificate of compliance.The homeowner sued in the District Court of Sweetwater County, asserting claims including breach of contract, negligence, and breach of warranty. During discovery, the homeowner failed to provide a specific calculation of damages, only indicating he would supplement disclosures later. Before trial, the contractor moved to exclude any evidence of damages not previously disclosed. The district court partially granted this motion, limiting the homeowner’s evidence to what had been disclosed. At a bench trial, the homeowner did not call his retained expert and offered only the total amount paid as the measure of damages. The district court concluded the oral contract was unenforceable due to indefinite terms and found insufficient evidence to support a damages award.On appeal, the Supreme Court of Wyoming affirmed the district court’s rulings. The Supreme Court held that, because the homeowner failed to make an offer of proof regarding excluded damages evidence, there was no basis to review the trial court’s exclusionary ruling. The court further held that the district court’s finding—that the homeowner did not prove damages by a preponderance of the evidence—was not clearly erroneous. As the damages element was not satisfied, the Supreme Court affirmed the dismissal of the claims. View "Lacher v. Case" on Justia Law

Several property owners and ranching entities challenged amendments adopted in 2023 by the Albany County Board of County Commissioners to the Aquifer Protection Overlay Zone (APOZ) regulations. The Casper Aquifer, which supplies drinking water to many residents of Albany County and the City of Laramie, had been the subject of prior regulatory efforts. The 2023 amendments included a 35-acre minimum lot size requirement and revised procedures for changing the APOZ boundaries. Appellants argued that the Board exceeded its authority, violated equal protection guarantees, and acted arbitrarily and capriciously in enacting the amendments.Previously, in Bienz v. Board of County Commissioners, County of Albany, 2024 WY 102 (Bienz I), the Wyoming Supreme Court reviewed whether amendments to the APOZ regulations were subject to direct judicial review under the Wyoming Administrative Procedure Act (WAPA). The district court had concluded it lacked jurisdiction, finding the Board's actions legislative and not reviewable under the WAPA. The Supreme Court reversed, holding that legislative agency actions are reviewable, and remanded the case for the district court to consider the merits. While litigation was pending, the Board further amended the APOZ regulations, requiring the district court to identify which amendments remained at issue. The district court ultimately upheld the Board’s authority and the amendments.On appeal, the Supreme Court of Wyoming addressed whether the Board exceeded its authority, whether the amendment procedures violated equal protection, and whether the arbitrary and capricious standard applied to agency legislative action. The Court held the Board acted within its statutory authority in protecting the Casper Aquifer, the distinct procedures for overlay zone amendments did not violate equal protection guarantees, and agency legislative actions are subject to the arbitrary and capricious standard. It concluded the 2023 APOZ amendments, including the 35-acre minimum lot size, were not arbitrary, capricious, or contrary to law, and affirmed the district court’s decision. View "Warren Livestock, LLC v. Board of County Commissione" on Justia Law

Two neighboring landowners, who are related by marriage, became involved in multiple property disputes, including disagreements over joint ownership and access to ditches and land. To resolve these disputes, one party filed two complaints in the District Court of Fremont County: one seeking an easement for ditch access and another seeking partition of jointly owned land. The parties also had related petitions pending before the Board of Control. During litigation, they participated in mediation and signed an email outlining terms of a purported global settlement agreement, which included provisions for access to ditches, maintenance rights, restrictions on visible storage, and the drafting of a formal settlement by one party’s attorney.After mediation, as the parties attempted to formalize the agreement, new disagreements arose regarding how to implement the access and storage restriction provisions. Each party filed a motion to enforce their interpretation of the settlement; one sought a recordable easement and restrictive covenant, while the other argued those terms exceeded the agreement. The District Court of Fremont County held a hearing to consider the motions, reviewed the parties’ filings and affidavits, and ultimately found that the agreement lacked essential terms, particularly regarding implementation of ditch access and the visual storage restriction. The court determined there was no meeting of the minds and denied both motions to enforce, as well as a request for sanctions.The Supreme Court of Wyoming reviewed the appeal. It held that the district court did not violate due process, as the issue of contract formation was properly considered and the parties had notice and opportunity to argue their positions. The Supreme Court agreed with the district court’s finding that no enforceable settlement agreement existed due to lack of mutual assent on material terms. It further held that Cross was not entitled to attorney’s fees, as there was no enforceable contract providing for such fees. The Supreme Court affirmed the district court’s order. View "Cross v. Albright" on Justia Law

Eric A. Wolfe and Brenda G. Wolfe, a married couple, acquired Lot 3, Lost Wells Butte Filing No. 1, in Fremont County, Wyoming, through a contract for deed. After the seller died without transferring title and with no probate estate opened, the Wolfes initiated a quiet title action in 2012. The district court issued a Judgment and Decree Quieting Title, naming them "husband and wife" and confirming their ownership of Lot 3, free of any claims from the seller’s heirs. Mr. Wolfe later passed away in January 2025, after which Mrs. Wolfe filed an affidavit asserting sole ownership of Lot 3 as a surviving tenant by the entirety.Ms. Lewis, their daughter, filed a declaratory judgment action in May 2025, claiming the 2012 judgment created a tenancy in common, not a tenancy by the entirety, and that Mr. Wolfe’s share should pass to his estate. Mrs. Wolfe moved to dismiss, arguing that Wyoming law presumes a conveyance to “husband and wife” creates a tenancy by the entirety, and that the statutory and common law requirements were met. The District Court of Fremont County found the judgment was a conveyance under Wyoming Statute § 34-1-102 and, applying § 34-1-140(b), held that the language “husband and wife” established a tenancy by the entirety. The court dismissed Ms. Lewis’s complaint.The Supreme Court of Wyoming reviewed the dismissal de novo. It concluded that the law in effect in 2012, as clarified in subsequent statutes and prior Wyoming decisions, recognized a presumption that a conveyance to “husband and wife” creates a tenancy by the entirety unless otherwise specified. The Court held that the Judgment and Decree Quieting Title manifested intent to create a tenancy by the entirety, making Mrs. Wolfe sole owner upon Mr. Wolfe’s death. The Supreme Court affirmed the district court’s dismissal of Ms. Lewis’s complaint. View "Lewis v. Wolfe" on Justia Law

Richard Q. Navarro and his son-in-law, Antonio Oros-Garcia, jointly owned two vehicles, a 2011 Dodge RAM pickup and a 2017 Dodge Challenger, as joint tenants with rights of survivorship. Navarro paid the entirety of the loans used to finance the vehicles. Subsequently, Oros-Garcia became a fugitive and could not be found. Navarro, still in possession of the vehicles but unable to sell or transfer them due to the joint ownership, filed a lawsuit seeking a partition of the vehicles to resolve the ownership and allow him to act regarding the vehicles without interference.The District Court of Laramie County initially granted Navarro’s motion for entry of default after Oros-Garcia failed to respond. However, the court repeatedly requested a third-party valuation of the vehicles from Navarro to determine jurisdiction. When Navarro did not provide the specific valuation requested, the court dismissed the complaint on its own motion under W.R.C.P. 12(b)(6), concluding Wyoming’s partition statutes only applied to real property, not personal property, and suggested Navarro could seek relief through a replevin action.The Supreme Court of Wyoming reviewed the district court’s dismissal de novo and held that Wyoming law does not preclude partition of personal property merely because the statutes address only real property. The court found that, under common law, joint owners of personal property are entitled to seek partition, and the absence of a statute does not abrogate this right. Additionally, the court determined that partition actions are in rem or quasi in rem proceedings and fall within the jurisdiction of the district courts, not circuit courts, regardless of the property’s value. The Supreme Court of Wyoming reversed the district court’s dismissal and remanded for further proceedings. View "Navarro v. Oros-Garcia" on Justia Law

The case centers on a real estate transaction involving Ernest and Martha Anderson, who agreed to sell their property to Noah Messinger and Brandy Chaplin. The property was subject to a “first right of purchase” covenant held by Wyoming Fall Creek, LLC (WFC), which owned the neighboring lot. After the Andersons and Messinger entered into a purchase agreement, WFC expressed an interest in exercising its purchase right but ultimately did not finalize an agreement with the Andersons within the specified period. The Andersons and Messinger extended their closing date multiple times as they awaited resolution regarding WFC’s position. Eventually, the Andersons unilaterally terminated the contract with Messinger, citing his failure to close, and continued negotiations with WFC, which never resulted in a sale.The District Court of Teton County first reviewed the matter. It found that WFC had not timely exercised its first right of purchase, declared the Andersons’ termination of the contract with Messinger unjustified, and ordered specific performance of the purchase agreement. The court also found that WFC tortiously interfered with Messinger’s contractual rights and awarded Messinger attorney fees and costs, holding the Andersons and WFC jointly and severally liable for some of those fees, and WFC solely liable for the remainder. WFC’s actions were also deemed willful and wanton, justifying an award of punitive damages in the form of attorney fees.The Supreme Court of Wyoming reviewed the appeals. It affirmed the district court’s findings, holding that the Andersons breached the purchase agreement by terminating it without justification, and specific performance was properly ordered. The Supreme Court also upheld the finding that WFC intentionally and improperly interfered with Messinger’s contract. Finally, it concluded that the punitive damages award, including attorney fees against WFC, was not unconstitutional. The district court’s judgment was affirmed in all respects. View "Wyoming Fall Creek, LLC v. Anderson" on Justia Law

Several homeowners in subdivisions along the North Platte River disputed ownership of a strip of land, known as the “meander land,” that lies between a designated meander line (depicted in historical government surveys) and the current thread (centerline) of the river. Both sides had historically used this land as part of their backyards. The plaintiffs claimed title to this land under the meander line rule, arguing their property extended to the thread of the river, while the defendants asserted that deeds, subdivision plats, and a later quitclaim deed gave them title to the disputed area.The plaintiffs, who owned lots in the Red Butte Subdivision south of the river, initiated quiet title actions, which were consolidated in the District Court of Natrona County. The defendants owned adjacent property and a tract labeled “Park 10” in the Trails West Subdivision, which lies north of the river but was described as extending under the river to the meander line. The district court granted summary judgment for the plaintiffs, determining that the meander line rule applied and the plaintiffs’ property extended to the thread of the river, not just to the meander line.The Supreme Court of Wyoming reviewed the district court’s order de novo. It held that the meander line in the relevant deeds and plats was not the true boundary; rather, the property extended to the river’s thread, consistent with Wyoming law and the generally accepted meander line rule. The Court found no clear language in the deeds or plats fixing the boundary at the meander line. It further ruled that subdivision plats could not convey land not owned by the subdivider. Accordingly, the Supreme Court of Wyoming affirmed the district court’s grant of summary judgment, holding that the boundary between the parties’ properties is the thread of the North Platte River. View "Hein v. Carlson" on Justia Law

The dispute centers on a series of complex financial transactions involving a Wyoming family and their businesses, a local bank, and a commercial lender. The plaintiffs, including a married couple and their closely held LLC, entered into various loans and mortgages related to their commercial property and business operations. When financial difficulties arose—exacerbated by a downturn in the oil and gas industry—the parties restructured their debt, resulting in a 2017 mortgage and, after the operating company filed for bankruptcy, a 2019 settlement agreement. The plaintiffs later alleged that the bank and lender’s actions and omissions caused them to lose equity in both their home and commercial property, and the defendants counterclaimed for breach of the settlement agreement and sought attorney fees.The District Court of Natrona County dismissed or granted summary judgment for the bank and lender on all claims and counterclaims, finding the mortgage unambiguously secured two loans and the bank had no duty to release it after only one was repaid. It also concluded the plaintiffs could not establish justifiable reliance on any alleged misrepresentations, interpreted the settlement agreement as permitting (but not requiring) the lender to record the quitclaim deed after a sale period, and found no breach by the lender. The district court further ruled the plaintiffs breached the agreement by filing suit, thus entitling the bank and lender to attorney fees.On review, the Supreme Court of Wyoming affirmed the district court’s decisions dismissing the plaintiffs’ claims, holding the mortgage secured both loans and the bank acted within its rights. The Supreme Court, however, reversed the grant of summary judgment to the bank and lender on their counterclaims, finding that filing the lawsuit was not a breach of the settlement agreement or its implied covenant of good faith and fair dealing. Consequently, the award of attorney fees and costs to the bank and lender was also reversed. View "Adams v. ANB Bank" on Justia Law