Justia Wyoming Supreme Court Opinion Summaries

In this dispute between two neighboring Park County communities - the China Wall Tract and the Copperleaf Subdivision - the district court interpreted the China Wall Tract’s restrictive covenants in a manner that will allow Copperleaf property owners access to and through certain areas in the China Wall Tract. The Gumpel Family Trust, which owned property in the China Wall Tract, appealed. The Supreme Court affirmed, as modified, holding (1) the district court did not err in interpreting the covenants; but (2) the court’s holding is modified to clarify that an “invitee” and an “owner” do not share equivalent rights under the covenants. View "Gumpel v. Copperleaf Homeowners Ass’n, Inc." on Justia Law

Louise Galiher sued to quiet title to a portion of her property, alleging that the use of the disputed portion of her property by Dennis Johnson and his wife had been permissive. The Johnsons counterclaimed seeking to quiet title to the disputed parcel based upon adverse possession. After a bench trial, the district court concluded that the Johnsons had proven their adverse possession claim. The Supreme Court reversed, holding that the district court committed prejudicial error when it determined it could not consider Johnson’s out-of-court statements as evidence that his use of the disputed property had always been permissive. Remanded. View "Galiher v. Johnson" on Justia Law

David Halling and Joyce Halling each purchased from Brandon Bentley an undivided half interest in certain property. Joyce, individually and as president of MedCon, Inc. (MedCon), executed a promissory note and mortgage as security for the note in favor of Bentley and for the purchase price of fifty percent of the lot. David, individually and as manager of Professional Business Holdings, LP (PBH), executed a mortgage in favor of Bentley on PBH’s half interest as security for the purchase price of the other fifty percent. Thereafter, Bentley assigned his rights and interests in the PBH mortgage to a bank and his rights and interests in the MedCon note and mortgage to David Yovanovich. Yovanovich sued MedCon, alleging that it failed to pay the amount due under the note. The district court granted summary judgment for Yovanovich. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in concluding that Yovanovich had an enforceable contract against MedCon and that the Yovanovich assignment was not ambiguous; (2) the court’s damages calculation was not clearly erroneous; (3) the court erred when it failed to award prejudgment interest; and (4) the court did not err when it failed to specify post-judgment interest in its order. Remanded. View "Halling v. Yovanovich" on Justia Law

The parties in this case disputed title to certain mineral interests underlying certain property. The dispute arose out of a 1911 Laramie County tax assessment against Union Pacific’s mineral interests in the property and the county’s subsequent tax sale and issuance of a tax deed for the property. Family Tree Corporation, which claimed title to portions of the minerals, filed a complaint for quiet title and declaratory judgment against Three Sisters LLC, which also claimed an ownership in the minerals, and Anardarko Land Corporation. The district court quieted title to Family Tree based upon the 1912 tax sale. Anadarko appealed, arguing that the 1911 tax assessment against the minerals was unconstitutional, and therefore, the resulting tax sale and deed were void. The Supreme Court affirmed after drawing the line between a tax assessment defect that will render a tax deed void and one that will render the tax deed viable, holding (1) the error in Laramie County’s tax assessment against the minerals at issue rendered the resulting tax deed voidable, not void; and (2) accordingly, Anadarko’s challenge to the validity of the tax deed was barred by the statute of limitations. View "Anadarko Land Corp. v. Family Tree Corp." on Justia Law

After Crook County Weed and Pest Control District applied herbicides to control leafy spurge found on property owned by Bush Land Development Company and Victoria Bush (collectively, Bush), many trees in the area of the spraying died. Bush filed this inverse condemnation action in the district court alleging that it was entitled to just compensation for the loss of its trees as a result of the District’s improper application of herbicides. The district court dismissed Bush’s claim, concluding that the action was not proper under the inverse condemnation statute. The Supreme Court affirmed on other grounds, concluding that the inverse condemnation was not properly before the district court because Bush failed to exhaust its administrative remedies before claiming inverse condemnation. View "Bush Land Development Co. v. Crook County Weed & Pest Control District" on Justia Law

In 1951, the State issued two oil and gas leases covering land in Sublette County. One of these leases (the 505 Lease) covered 160 acres, and the other lease (the 529 Lease) covered 480 acres. The leases were later assigned to Continental Oil Company, and the assignor, Walter Davis, reserved a four percent overriding royalty interest in both leases. Davis’s mineral interests were later awarded to Robert Floyd. In 1979, after the 505 and 529 Leases terminated and the acreage was combined into a single parcel, the State granted Dr. Robert Ribbe Lease 79-0645, which covered all 640 acres. In 2011, Robert Floyd filed suit, arguing that Davis’s four percent overriding royal interest should have attached to the Ribbe Lease. The district court concluded that Appellants, QEP Energy Company and Wexpro Company, were liable for more than thirty million dollars in unpaid royalties. The district court denied Appellants’ motion for a new trial. The Supreme Court reversed, holding that the Ribbe lease was not a renewal lease, substitute lease, or new lease issued in lieu of the 505 and 529 Leases, and therefore, the overriding royalty interest did not attach to the Ribbe Lease. View "Questar Exploration & Production Co. v. Rocky Mountain Resources, LLC" on Justia Law

Appellees, the purported owners of the “Jay Ranch,” brought an action against Appellant to establish a private road across Appellant’s property. While this suit was pending, Appellees were involved in litigation to determine the rightful ownership the Jay Ranch. The district court concluded that Appellees had satisfied the statutory threshold requirements to move forward with their private road claim and granted Appellees temporary access to the road across Appellant’s property. Thereafter, a decision was rendered against Appellees in the litigation to determine ownership of the Jay Ranch. The district court subsequently dismissed the present case for lack of prosecution. Appellant filed a motion for an award of attorney’s fees and a motion for an award of compensation for the temporary road access. The district court denied both motions. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s post-judgment motion for attorney’s fees was not authorized under Wyo. R. Civ. P. 54; and (2) the district court did not have jurisdiction to consider Appellant’s motion for compensation. View "Edsall v. Moore" on Justia Law

Appellants, the owners of a tract of land in the Riva Ridge subdivision, submitted their plans to build a home and writer’s studio to the Riva Ridge Owners Association’s Site Committee. The Site Committee rejected the plans on the basis that some of Appellants’ home would be visible from some locations in other homes. Appellants filed a complaint against the Association and others (collectively, Appellees) alleging several causes of action. Appellants filed a separate complaint requesting a determination of the term “principal residence site” in the covenants. The district court granted summary judgment for Appellees on several issues. After a trial, the district court interpreted the phrase “principal residence site” in a way that required complete invisibility between the homes in the subdivision. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) erred in its interpretation of the phrase “principal residence,” as the covenants only require that a principal residence be invisible only from a precise area of land on each tract; (2) erred in granting summary judgment on Appellants’ breach of contract and bad faith claims; and (3) properly determined that Appellants must seek permission from the Site Committee before planting any trees on their tract. View "Felix Felicis, LLC v. Riva Ridge Owners Ass’n" on Justia Law

Jason and Tracy Thornock (together, Plaintiffs), who owned a ranch in Lincoln County, filed a complaint against neighboring landowners (Defendants), alleging that their property was landlocked and requesting establishment of a private road. After a bench trial, the district court denied the complaint, concluding that Plaintiffs failed to establish the necessity for a private road because they did not prove that their property was landlocked or that their access was substantially inconvenient. The Supreme Court affirmed, holding that the district court did not err in finding that Plaintiffs failed to establish the need for a private road because the record showed that Plaintiffs had direct access to their property via a public road that provided convenient and reasonable access. View "Thornock v. Esterholdt" on Justia Law

Contractor Anderson Carpentry and Construction built a home for Shad and Trisha Bates. Anderson contracted with Century Lumber Center to purchase supplies and materials to build the Bates home. The Bates paid Anderson for materials used on the home, but those funds were applied to other accounts, and the account with Century on the Bates job became delinquent. Century filed a material lien against the Bates property and filed a complaint seeking to foreclose the lien against the property. The district court ultimately enforced the lien. The Supreme Court reversed, holding that the lien was not timely filed as a matter of law. View "Bates v. Chicago Lumber Co. of Omaha" on Justia Law