Justia Wyoming Supreme Court Opinion Summaries

The Thornhocks filed an action against the Esterholdts and others seeking to quiet title to certain lands in Lincoln County. The district court granted summary judgment to the Thornocks as to some of the land but denied summary judgment as to a certain strip of property. After a bench trial, the district court quieted title in the disputed strip of land in the Esterholdts. The Supreme Court affirmed, holding (1) an appurtenant easement was not created by a deed that granted, in addition to tracts of fee title land, also that "right of way to be used in connection with said land"; and (2) an appurtenant easement was not created by a deed that granted a "right-of-way" described as the land now in question. View "Thornock v. Esterholdt" on Justia Law

In 2006, Teton County voters approved a Teton County Housing Authority (TCHA) sponsored ballot initiative enabling a specific purpose excise tax (SPET) to raise $5 million for TCHA's affordable housing program. In 2007, TCHA purchased a five-acre property on Cheney Lane. Later that year, Plaintiffs, residents of the Cheney Lane neighborhood, initiated a declaratory judgment action against TCHA, alleging violations of SPET limitations, breach of investment duties, and violations of Wyoming statutory limits on public financing. Two weeks after the district court heard arguments on the motion to dismiss, the Village Road Coalition (VRC), a nonprofit corporation consisting of residents of a neighborhood near the Cheney Lane property, filed a motion to intervene. The district court denied the motion. The court subsequently granted TCHA's motion to dismiss the complaint for lack of standing. The Supreme Court affirmed, holding (1) because VRC's interests and relief sought were duplicative of those presented by Plaintiffs, the district court did not err in denying the motion to intervene; and (2) the district court properly dismissed TCHA's action for lack of standing, as Plaintiffs failed to allege a tangible interest that had been harmed by the acquisition of the property. View "Village Road Coal. v. Teton County Hous. Auth." on Justia Law

In 2001, Plaintiff offered to purchase a commercial property. Defendant was the real estate agent who prepared the offer. The sellers accepted the offer to purchase and prepared a property disclosure statement in compliance with the contract requirement. Plaintiff became the sole owner of the property in 2004. Two years later, Plaintiff discovered three inches of water in the building basement that had leaked through the west wall of the foundation of the building. In 2012, Plaintiff filed a complaint against Defendant, alleging he was negligent in failing to provide the property disclosure statement. The district court dismissed the action on account of the two-year statute of limitations having expired. Plaintiff appealed, arguing that the district court erred in ruling that Defendant had no duty to disclose or provide the property disclosure statement. The Supreme Court dismissed the case due to Plaintiff's failure to challenge the statute of limitations ruling by the district court. The Court also noted that the district court acknowledged that Defendant owed Plaintiff a duty to deliver the disclosure statement. View "Ferrell v. Knighten" on Justia Law

Greencore Pipeline Company filed an action seeking to condemn easements across property owned by Barlow Ranch for a pipeline to transport carbon dioxide. The parties reached an agreement on the terms of possession and scope of the easements but disputed the amount that would justly compensate Barlow for the partial taking of its property. During trial, Barlow presented evidence of prices paid for other comparable pipeline easements to show the air market value of Greencore's easement. The district court awarded compensation based upon the average of the amounts Greencore had paid other landowners for easements for its carbon dioxide pipeline. Both parties appealed. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) properly ruled that it could consider evidence of comparable easements in determining just compensation; (2) erred in concluding Barlow's proffered easements were not the result of arms' length transactions or sufficiently comparable, while the other Greencore easements were; (3) erred by concluding annual payments were not allowed under Wyoming law; and (4) correctly ruled that the issue of whether Greencore may abandon the pipeline in place was not properly before the Court. View "Barlow Ranch, LP v. Greencore Pipeline Co., LLC" on Justia Law

While a lawsuit by Appellees David and Elizabeth Speaks was pending against Rosemary and Byron Baker for damages related to poor construction workmanship, the Bakers transferred two parcels of real property to their son, Nathan Baker. The case resulted in a judgment against Byron but a dismissal of the claims against Rosemary. The appellate court affirmed the trial court's decision. Five days later, Nathan transferred the properties to a limited liability company (LLC) he and his family controlled. Appellees subsequently filed this case under the Uniform Fraudulent Conveyance Act and the Uniform Fraudulent Transfer Act. While the case was pending, the LLC transferred the two pieces of property to trusts controlled by Rosemary Baker. The district court granted summary judgment for Appellees permitting execution on the properties, finding that all of the conveyances were fraudulent. The Supreme Court reversed and remanded, holding (1) the district court correctly found the conveyances to be fraudulent; but (2) Appellees failed to make the required prima facie showing that the properties were subject to execution on a judgment against Byron Baker alone. View "Baker v. Speaks" on Justia Law

Landowners' neighbors filed with the Board of County Commissioners a petition for establishment of a county road along an unsurveyed legal description that closely equated to Landowners' driveway. The Board dismissed the petition, determining that Landowners' driveway already was part of a previously established county road. The district court remanded to the Board to conduct a survey of the county road to determine whether Landowners' driveway was indeed part of the county road. Upon remand, rather than obtaining a survey of the driveway or county road as ordered, the Board declared that the driveway was part of the county road. The district court again remanded. Some time later, the county attorney informed Landowners that the Board did not intend to change its position that Landowners' driveway was part of the existing county road. Landowners sued the Board for inverse condemnation, trespass, and ejectment. The district court granted summary judgment to the Board, concluding that the inverse condemnation claims were barred by limitations and that the trespass and ejectment claims failed as a matter of law. The Supreme Court reversed the district court as to the inverse condemnation claims, holding that Landowners' claims were filed within the applicable statute of limitations. Remanded. View "Smith v. Bd. of County Comm'rs" on Justia Law

C&J, LLC owned 2.04 acres of property. The northern portion was zoned for commercial use, and the southern portion was zoned for a single-family residence. C&J filed an application requesting approval to develop the single-family residential zone. The Teton County Board of Commissioners approved C&J's final development plan application allowing C&J to construct five residential units and one affordable housing unit in the single-family residential zone. It also allowed commercial parking and other commercial uses. Appellant Wilson Advisory Committee, a non-profit corporation representing citizens concerned about the development of Wilson, petitioned for judicial review. The district court affirmed the Board's decision. The Supreme Court affirmed in part and remanded to require the Board to make findings called for by its own regulations as to whether or not the proposed location and density improved scenic views and lessened adverse environmental impacts. View "Wilson Advisory Comm. v. Bd. of County Comm'rs" on Justia Law

Roundup Heights, a subdivision in Laramie County, was located within one mile of the City of Cheyenne. The owners of certain lots applied for County approval of a partial vacation of the subdivision plat. The County granted the partial vacation without City approval despite the City's contention that the partial vacation required joint approval by both the City and the County. The City filed suit, seeking declaratory judgment that joint City and County approval was required for partial vacation if the affected land was within one mile of the City. The district court granted summary judgment in favor of the County. The Supreme Court affirmed, holding that the relevant statutes unambiguously do not require joint City and County approval of partial vacations if the affected property is wholly within the County. View "City of Cheyenne v. Laramie County Bd. of Comm'rs" on Justia Law

These consolidated appeals stemmed from the Redland family's dispute over ranch property and operations. Two of the appeals related to real property that some of the Redland children claimed their father, Robert Redland, agreed to place in a family trust. The district court granted Robert partial summary judgment, holding that the claims were barred by the statute of limitations and statute of frauds. A bench trial was held on the remaining issues. The trial court ruled against Robert on his two sons' unjust enrichment claims for improvements they had made to the disputed trust properties and also ruled against Robert on his counterclaim against another child and his wife for a partnership interest in their cattle operation. In the remaining appeal, Robert appealed the trial court's rulings on the unjust enrichment and partnership claims. The Supreme Court (1) reversed the grant of summary judgment, holding that disputed issues of material fact existed on the questions of whether the Redland children's property claims were barred by the state of limitations or statute of frauds; and (2) affirmed the district court's ruling on the unjust enrichment claims and the partnership claims. Remanded. View "Redland v. Redland" on Justia Law

After Swan Ranch was annexed by the City of Cheyenne in 2009, Appellants, neighbors to the land being annexed, filed a declaratory judgment action against the City alleging that the annexation was invalid under Wyo. Stat. Ann. 15-1-402(a). Ultimately, the district court granted the City's responding summary judgment argument on two claims and conducted trial on the third and final claim. Following trial, the district court found the annexation was proper. The Supreme Court affirmed, holding that the district court's decision upholding the Swan Ranch annexation was not clearly erroneous, as "the degree of contact, the location, and the character of the annexed parcel" were sufficient to satisfy the statutory requirements for annexation under section 15-1-402. View "Hough v. City of Cheyenne" on Justia Law