Justia Wyoming Supreme Court Opinion Summaries

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

Plaintiffs were several residents in the Milatzo Subdivision who sought to permanently enjoin Defendants from operating a daycare business out of their residence in the Subdivision. The district court granted Plaintiffs’ request for a permanent injunction, concluding (1) Defendants’ daycare operation violated the protective covenants governing properties in the Subdivision, (2) Defendants did not establish that those covenants had been abandoned, and (3) the violation harmed Plaintiffs. The Supreme Court affirmed, holding that the district court did not err in finding that the protective covenants governing the Subdivision were not abandoned and that Defendants flagrantly ignored the covenants when they opened their daycare operation. View "Moore v. Wolititch" on Justia Law

Appellants, property owners in Ryan Park and members of the Ryan Park Property and Homeowners Association, commenced an action claiming that the Association had unlawfully denied their requests to inspect and copy certain Association records. Appellants moved for an order allowing them to inspect and copy the documents, and also sought costs and attorney’s fees. The district court ordered the Association to make the documents available for copying and inspection but declined to order the Association to pay attorney’s fees or costs. On appeal, Appellants contended that the denial of attorney’s fees and costs was contrary to the provisions of the Wyoming Nonprofit Corporation Act. The Supreme Court affirmed, holding that the district court did not err in finding that the Association had made reasonable efforts to satisfy Appellants’ requests and in finding that the Association did not act in bad faith. View "Clark v. Ryan Park Prop. & Homeowners Ass’n" on Justia Law

In 2011, Ted Price, as Trustee of the Price Family Trust, filed an application for the establishment of a private road asserting that his property had no outlet to or connection with a public road. The Crook County Board of Commissioners denied the application on the ground that Price already had access to his property from at least two existing public roads. The district court affirmed. The Supreme Court affirmed, holding (1) the Board’s decision denying Price’s private road application was supported by substantial evidence, the actions of the Board were not arbitrary or capricious, and the record did not establish the level of inconvenience required to establish necessity; and (2) the district court did not err in denying Price’s request that the final result be set aside due to malfunctioning audio equipment. View "Price v. Hutchinson" on Justia Law

Disagreements as to the operation of a family ranch led to this partition action. The district court found that the parties were entitled to partition and ordered the construction of a new ditch to carry the water Appellant received to her parcel of land. The Supreme Court reversed, holding that the district court’s order was not sufficiently complete to establish that a partition in kind could be made without manifest injury to the value of the property and that the division was equitable to all parties. Remanded for a determination whether the land can be partitioned in kind without manifest injury to its value. View "Platt v. Platt" on Justia Law

Landowners Merlin and Lori Zowada filed a petition with the Board of County Commissioners to establish a private road to access their landlocked tract of property through property owned by Mullinax Concrete Service Company. The Board considered six alternative routes for the private road. After the Board ruled on the petition, the Supreme Court determined that the case should be remanded to the commissioners to compare the relative merits of only two alternative routes, Route 1 and Route 6, and to determine whether the greater cost of Route 6 was justified. After further proceedings, the Board established the road along Route 6. The Zowadas sought review of that decision. The Supreme Court affirmed the Board’s findings of fact and conclusion of law, holding that the Board’s decision to establish the private road along Route 6 was supported by substantial evidence. View "Zowada v. Mullinax Concrete Serv. Co., Inc." on Justia Law