Justia Wyoming Supreme Court Opinion Summaries

This proceeding was the third and final phase of the general adjudication of water rights in the Big Horn River. The State recommended adjudicating water rights for fifty-two acres of land owned by Hat Bar Cattle Company. Neighboring landowner Betty Whitt objected to the recommendation. After a contested case hearing, the Special Master recommended adjudicating the right to irrigate the fifty-two acres at issue. The district court adopted the Special Master’s report and recommendation and adjudicated Hat Bar’s rights. Whitt appealed. The Supreme Court affirmed, holding that the Special Master correctly applied the burden of proof and that the finding regarding beneficial use of the water were not clearly erroneous. View "Whitt v. Hat Bar Cattle Co." on Justia Law

In 2012, the Fremont County Assessor assessed the commercial land and improvements of Mountain Vista Retirement Residence at $1,327,908 and its personal property at $8,246. The Fremont County Board of Equalization, the State Board of Equalization, and the district court upheld the valuation. Mountain Vista appealed, arguing that it should be exempt from property tax because it is a charitable or benevolent association that uses its property for primarily non-commercial purposes. The Supreme Court affirmed, holding that Mountain Vista is neither a charitable or benevolent association and that its property is primarily used for commercial purposes. View "Mountain Vista Ret. Residence v. Fremont County Assessor" on Justia Law

In the third and final phase of the general adjudication of water rights in the Big Horn River, the Wyoming Board of Control recommended elimination of certain unused and unadjudicated water rights under Farmers Canal Permit 854, including that rights to irrigate Tract 109. Frank Mohr, the owner of Tract 109, objected, admitting that Tract 109 had never been adjudicated under the Farmers Canal Permit but was adjudicated under the Perkins Ditch Enlargment Permit. In conjunction with his application for that permit, Mohr’s predecessor submitted an affidavit relinquishing his right to water under the Farmers Canal Permit. The Special Master recommended elimination of Tract 109 from the Farmers Canal Permit, finding that relinquishment of the Farmers Canal Permit by Mohr’s predecessor was final and not subject to attack by Mohr. The district court approved the Special Master’s recommendation, concluding that Tract 109 was serviced under the Perkins Ditch Enlargement and not the Farmers Canal Permit. The Supreme Court affirmed, holding (1) Mohr was bound by the acts of his predecessor-in-interest and the previous adjudication of water rights to Tract 109; and (2) the district court gave Mohr a fair opportunity to present his case in accordance with the Wyoming Rules of Civil Procedure. View "In re Gen. Adjudication of All Rights to Use Water in Big Horn River Sys." on Justia Law

Appellee filed the instant action for declaratory relief, claiming to have title to eighty percent of the mineral interest in certain Converse County, Wyoming property pursuant to a 1976 judgment and asserting that Appellants were barred under the doctrine of res judicata from claiming any interest in the property. Appellants argued that only the surface was at issue in the 1976 quiet title action. The district court concluded that res judicata barred Appellants’ current claim because the 1976 proceeding addressed the mineral interest. The court then granted summary judgment in favor of Appellee, concluding that its predecessor acquired title to the mineral interest in the 1976 action, which was not contested by Appellants’ predecessors. The Supreme Court affirmed, holding (1) the district court properly ruled that Appellants were barred from asserting that they owned the mineral interest; and (2) this dispute did not present an appropriate case for the application of laches. View "Clay v. Mountain Valley Mineral Ltd. P’ship" on Justia Law

Malcolm and French Wallop created an estate plan with the intention of owning and operating the Canyon Ranch and establishing a means of transferring its ownership and operation to their respective children. The estate plan led to the formation of the Wallop Family Limited Partnership (WFLP), which owned and operated the Canyon Ranch. Malcolm and French also formed Wallop Canyon Ranch, LLC (WCR) to serve as the general partner of the WFLP. Scott Goodwyn, individually, as a limited member in the WFLP and derivatively on behalf of the WFLP, sued Malcolm Wallop, WCR, the WFLP, and other Wallop family members, alleging breaches in the ownership, operation, and management of the WFLP. The district court (1) found generally in favor of Goodwyn on his claims relating to gifts made to him and other limited partners; (2) found generally against Goodwyn on his claims of breach of fiduciary duties by certain defendants; and (3) determined that the gifting issues upon which Goodwyn prevailed were derivative claims and that Goodwyn was entitled to reasonable attorney’s fees relating to the derivative claims. The Supreme Court affirmed, holding that the district court did not err in (1) awarding attorney’s fees; and (2) denying Goodwyn’s claims of breach of fiduciary duties by certain defendants. View "Goodwyn v. Wallop" on Justia Law

Buyer agreed to purchase a portion of a 2,700 acre ranch from Sellers. Sellers agreed to finance a portion of the purchase price by accepting Buyer’s promissory note. After Buyer defaulted on the promissory note, Sellers initiated foreclosure proceedings. Buyer and its successor in interest (collectively, Buyers) filed a complaint for declaratory judgment and a motion for a temporary restraining order to halt the foreclosure, asserting several causes of action. Sellers counterclaimed, asserting that Buyers breached the terms of the promissory note. The district court granted summary judgment in favor of Sellers. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in granting summary judgment in favor of Sellers with respect to Buyers’ adverse possession claim and with respect to Sellers’ breach of contract claim; and (2) erred in denying Sellers’ request for attorney’s fees. Remanded. View "Flynn v. Ruby River Canyon Ranch, Ltd." on Justia Law

Gregory and Debra Lavitt and Harry Stephens owned mountain property near one another. Stephens commenced a declaratory judgment action seeking a ruling that he held a valid easement across the Lavitts’ property. The district court determined that Stephens held a valid easement. When Stephens violated the conditions imposed on his use of the easement, the district court terminated the easement. Stephens then filed a complaint in district court requesting that the court condemn a private road allowing access to his land-locked property. Stephens proposed a route traversing the portion of the Lavitts’ property where his former easement lay. The district court concluded that Stephens had created his own lack of access, precluding him from seeking a road across the Lavitts’ property. The court declined to award sanctions against Stephens or his attorney and also denied the Lavitts’ motion requesting attorney’s fees. The Supreme Court affirmed, holding that the district court did not abuse its discretion (1) when it denied the Lavitts’ motion for costs and attorney’s fees pursuant to Wyo. R. Civ. P. 41(d), as such an award was not available in this case; and (2) in deciding not to impose sanctions against Stephens and his attorney pursuant to Wyo. R. Civ. P. 11, as Stephens’ complaint was not frivolous. View "Lavitt v. Stephens" on Justia Law

At issue in this case was the Redland family’s dispute over ranch property that some Redland children (“Children”) claimed that their father (“Father”) agreed to place in a family trust. In the first appeal, the Supreme Court concluded that the district court erred in entering summary judgment, as questions of fact existed on the issues of whether Children’s claims against Father were barred by the statute of frauds and the statute of limitations. On remand, the district court determined that Children’s claims were not barred and ordered that the disputed property, with the exception of property on which Father resided (“residential property”), be immediately transferred to the family trust. With regard to the residential property, the court ordered that the property be transferred to the trust upon Father’s death. The Supreme Court affirmed as modified, holding that the district court (1) did not err in holding that an enforceable agreement existed that required placing the disputed property in the trust; (2) did not err in determining that the statute of limitations did not bar Children’s claims; and (3) erred in its disposition of the residential property. Remanded with directions that the residential property be immediately transferred to the family trust subject to Father’s life estate in the property. View "Redland v. Redland" on Justia Law

In 1920, the Beckton Ranch Trust (BRT) was formed by members of the Forbes family to hold parcels of land in Sheridan County, Wyoming and their appurtenant water and ditch rights for the benefit of their descendants. In 2007, Waldo Forbes (Spike) resigned as trustee after a dispute with his siblings. Later that year, the remaining trustees - Spike’s brother, Cam, and his sisters, Julia, Sarah, and Edith - began a series of land and water transactions. Spike subsequently sought the removal of the trustees. The district court (1) concluded that Cam and Julia had breached their duty of loyalty and should be removed as BRT trustees; and (2) made no finding as to Sarah and Edith, and therefore, they continued as BRT trustees.The Supreme Court reversed in part and affirmed in part, holding (1) Cam and Julia breached their duty of loyalty, but because the evidence did not demonstrate that they acted dishonestly or with want of capacity, or that any serious harm had been done, the breaches did not warrant their removal as trustees; and (2) the district court correctly decided not to remove Sarah and Edith. View "Forbes v. Forbes" on Justia Law

After purchasing their property, William and Tia Hansuld notified Lariat Diesel Corporation and Marvin Piel (collectively, “Lariat”) that it could not longer use their property for access. Litigation ensued. This matter was the third appeal of the parties’ various claims to the Supreme Court. In Hansuld I, the Court concluded that Lariat had an implied easement for access across the Hansulds’ property. On remand from Hansuld II, the district court conducted a bench trial to establish the specific location of Lariat’s implied access easement. The district court applied the law of floating easements to determine the location of Lariat’s implied access easement and accepted one of Lariat’s proposed locations with some modification. The Supreme Court affirmed, holding (1) the district court incorrectly recited the law pertaining to floating easements, but the error did not make a legal difference; and (2) the Hansulds did not demonstrate that the district court’s final decision as to the location of the implied easement was either clearly erroneous or that the court erred as a matter of law. View "Hansuld v. Lariat Diesel Corp." on Justia Law