Justia Wyoming Supreme Court Opinion Summaries

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

This third appeal concerned a judgment obtained by David and Elizabeth Speaks against Byron Baker. Two properties, the Corsi Ranchettes lot and the Misty Meadows lot, were fraudulently transferred by Byron and Rosemary Baker to their son, Nathan, who, in turn, transferred the properties to Bryner Farms, LLC, a family-owned company, which conveyed the properties to Pat’s Dream Project Trust and MME Trust (collectively, “the Baker Defendants”). The Baker Defendants asserted the property was exempt from execution from the judgment against Byron, alone, because it was held by Byron and Rosemary as tenants by the entirety. The district court concluded (1) the Bakers were not married when they took title to the Corsi Ranchettes property, and therefore, Byron’s interest was not entitled to protection from legal process; and (2) the Speaks brought the action to declare the Misty Meadows property transaction fraudulent within the applicable limitations period. The Supreme Court affirmed, holding (1) the district court properly found that the Speaks were entitled to execute on Byron’s interest in the Misty Meadows lot; and (2) the district court did not err in concluding that the Bakers could not create a valid tenancy by the entirety with regard to the Corsi Ranchettes lot. View "Baker v. Speaks" on Justia Law

The Star Valley Ranch Association mounted an effort to amend the restrictive covenants governing the Star Valley Ranch subdivision. Appellees, owners of property in the subdivision, challenged the validity of the amended covenants by filing suit in the district court. Specifically, Appellees sought a declaration that the amendments were invalid because the Association had not complied with the previous covenants’ requirements for amendments. Appellees also sought an injunction prohibiting the Association from implementing and enforcing the amended covenants. The district court granted summary judgment for Appellees. The Supreme Court affirmed, holding (1) the district court did not err in holding that the amended covenants were invalid; (2) the Association’s claim of impracticability failed; and (3) Appellees had standing to challenge the amendments as a single, unified set of covenants applicable to the entire subdivision. View "Star Valley Ranch Ass’n v. Daley" on Justia Law

Appellant owned property as a tenant in common with Appellees, two relatives. Both parties sought to partition the property. The district court concluded that Appellant ousted Appellees from the property and, therefore, must pay them a fair rental value for the use of the property. Appellees became the successful bidders of the property at a second public sale, and the district court approved the sale. The Supreme Court affirmed, holding (1) the district court properly held that Appellant ousted the cotenant Appellees and must pay them the fair rental value for the time she exclusively occupied the property; (2) the district court’s calculation of the total amount of rent Appellant owed the cotenants was not clearly erroneous; (3) Appellees were entitled to bid at the public sale of the partitioned property and were entitled to bid the value of their interests in the property and a portion of the monetary award for rent in lieu of payment; and (4) Appellant was not entitled to a homestead exemption even though she occupied the partitioned property at times. View "Martin v. Prieto" on Justia Law

In this adverse possession case, Henry and Simona Prado purchased a lot in 1966 and used a strip of land under the mistaken belief that the land was theirs. In 1989, Tracy and Norma Lampman brought the lot to the east of the Prados that included the narrow parcel. The owners of each lot each apparently believed they owned the strip of land. In 2011, Christopher and Tami Graybill entered into a contract for deed with the Prados, took possession of their lot, and began using the disputed strip of land. When a survey established the true property line, the Lampmans fenced off the disputed parcel. The district court quieted title in the Lampmans, concluding that the Graybills and the Prados (collectively, Appellants) did not own the disputed area by adverse possession. The Supreme Court reversed, holding that Appellants established their adverse possession claim by a preponderance of the evidence, and the district court erred in finding to the contrary. Remanded. View "Graybill v. Lampman" on Justia Law

Frank Forelle and William Fix were neighbors in a subdivision. After Forelle built a fence on his property along the border of the parties’ adjoining properties, Fix complained that the fence violated the subdivision’s covenants. Fix, an attorney who represented himself in the matter, prevailed on his claim in the district court. Relying on a covenant provision regarding reimbursement for costs incurred in enforcing the covenants, Fix subsequently sought attorney fees. The district court awarded Fix attorney fees, but later, in an amended judgment, concluded that Fix could not recover fees for the legal work he performed because he did not actually incur any fees. The Supreme Court affirmed, holding that because Fix was never liable for or subject to his own attorney fees, he did not incur any fees, and therefore, Fix was not entitled to recover attorney fees for the work he performed in the litigation. View "Fix v. Forelle" on Justia Law