Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the district court’s grant of summary judgment in favor of Plaintiff in this declaratory judgment action against the Board of County Commissioners of Teton County challenging the Teton County Land Development Regulation prohibiting fractional ownership of campgrounds, holding that the regulation was unenforceable because it exceeded the County’s zoning authority. Specifically, the Court agreed with Plaintiff that the regulation prohibiting fractional ownership did not regulate the use of the land, only its ownership, and was, therefore, beyond the County’s zoning authority and unenforceable. View "Board of County Commissioners of Teton County, Wyoming v. Mackay Investments, LLC" on Justia Law

In this dispute over Plaintiffs’ right to prepay a contract for deed and Defendant’s obligation to deliver the deed, the Supreme Court affirmed the district court’s rulings in favor of Plaintiffs. The district court ruled in favor of Plaintiffs and ordered Defendant to pay attorney fees and costs for discovery violations. The Supreme Court agreed with Plaintiffs’ statement of the dispositive issues, holding (1) Defendant's appeal of the declaratory judgment ruling was untimely; (2) the district court properly awarded fees and costs for failure to present cogent argument or pertinent authority; and (3) Plaintiff should be awarded sanctions pursuant to Wyo. R. App. P. 10.05. View "Byrnes v. Harper" on Justia Law

The Supreme Court summarily affirmed the district court’s order recognizing and adopting the settlement Richard Hodson reached with Janet Sturgeon. In the settlement, the parties agreed to resolve their pending lawsuit and to divide their jointly owned property. Hodson challenged the district court’s order adopting the settlement through this pro se appeal, apparently arguing that the district court erred in refusing to enforce an agreement that allegedly existed before he filed his lawsuit. The Supreme Court held that Hodson failed to comply with the court’s rules of appellate procedure, and therefore, summarily affirmed the district court’s order. The court also granted Sturgeon’s request for an award of costs and attorney fees. View "Hodson v. Sturgeon" on Justia Law

The Supreme Court reversed the judgment of the district court entering summary judgment in favor of Defendants in this complaint filed by Plaintiffs asserting a claim for adverse possession based on Plaintiffs’ fencing and grazing of livestock on a strip of Defendants’ property. The Supreme Court held (1) genuine issues of material fact existed with respect to Plaintiffs’ prima facie adverse possession claim, and therefore, the district court did not err in denying Plaintiffs’ motion for summary judgment on this claim; and (2) the district court erred in granting Defendants summary judgment on their claim that Plaintiffs’ use of the disputed property was permissive. View "White v. Wheeler" on Justia Law

The Supreme Court affirmed the decision of the Teton County Board of County Commissioners granting Four Shadows, LLC a basic use permit (BUP) to use its property in Teton Village for temporary construction storage/staging. The court held (1) Appellants had an interest that was greater than the general public’s, giving them standing to maintain their appeal as persons aggrieved and adversely affected in fact by the Board’s decision to issue the permit; and (2) the Board’s decision to grant Four Shadows a BUP for temporary use of the property for construction storage/staging was not arbitrary, capricious, an abuse of discretion, or otherwise contrary to law. View "Tayback v. Teton County Board of County Commissioners" on Justia Law

Appellants owned residential property in Teton County. JCFT Wyoming Real Estate, LLC owned two parcels in the same area. The Teton County planning director, at Appellants’ request, issued a formal rule interpretation concerning a development permit associated with the JCFT property. At JCFT’s request, the planning director issued a zoning compliance verification (ZCV) concerning JCFT’s smaller parcel. Appellants appealed the rule interpretation and the ZCV decision. The Teton County Board of County Commissioners dismissed the appeals, concluding that Appellants lacked standing to appeal either action. The district court affirmed. The Supreme Court affirmed, holding (1) Appellants lacked standing to challenge the Teton County planning director’s rule interpretation and ZCV decision; and (2) neither decision was ripe for judicial review. View "Moose Hollow Holdings, LLC v. Teton County Board of County Commissioners" on Justia Law

Appellants sought the establishment of a private road along the upper portion of Black Mountain Road in Big Horn County, but the Big Horn County Board of County Commissioners established a private road along the lower portion of Black Mountain Road. Appellants argued that the route was illogical, unproductive, and uneconomic and was procedurally barred. The Supreme Court affirmed, holding (1) because the district court’s earlier decision in a decision letter did not address the question of whether the proposed private road was reasonable or convenient, collateral estoppel and law of the case did not apply; and (2) the Board’s conclusion that Lower Black Mountain Road was more reasonable and convenient than Upper Black Mountain Road was supported by substantial evidence. View "Whaley v. Flitner Limited Partnership" on Justia Law

Clare Sikora filed a declaratory judgment action against the City of Rawlins challenging the City’s issuance of a building permit to her next-door neighbors, Jared and Kasandra Ramsey. The district court ruled in favor of the City. The Supreme Court affirmed, holding (1) the district court properly found that Sikora failed to exhaust her administrative remedies; and (2) the district court did not err in finding that the the municipal ordinance governing restoration of a nonconforming building allows for demolition of the nonconforming building and reconstruction of the building within the same footprint - the type of construction undertaken by the Ramseys. View "Sikora v. City of Rawlins" on Justia Law

In this dispute between property owners regarding a mistaken property boundary, the district court concluded that Appellees had acquired title to the property at issue by adverse possession. The Supreme Court affirmed, holding (1) contrary to Appellants’ arguments, Appellees’ possession of the property was “hostile,” and the conveyance of the property to Appellants by their predecessors in interest did not divest Appellees of any claim they had to the property by adverse possession; and (2) Appellees’ request for sanctions under Wyo. R. Civ. P. 10.05 is denied because the Court cannot certify that Appellants had no reasonable cause for this appeal. View "Osuch v. Gunnels" on Justia Law

The Supreme Court answered a question of law regarding the relative priority of liens against real property as follows: A lien against real property created by a certificate of purchase for delinquent taxes pursuant to Wyo. Stat. Ann. 39-13-108(d)(ii) is superior to any lien held by the State of Wyoming, Department of Workforce Services under Wyo. Stat. Ann. 27-3-511(b) for unpaid contributions and interest to the unemployment compensation fund. The question was certified to the Court by the United States District Court for the District of Wyoming and conceded real estate in Uinta County and encumbrances against the property arising from the failure of a corporation to satisfy various financial obligations. View "Brock v. State, ex rel. Wyoming Workforce Services, Unemployment Insurance Division" on Justia Law