Justia Wyoming Supreme Court Opinion Summaries

Summit Construction filed a lawsuit against Jay Koontz and Jennie L. Kennette for breach of contract and unjust enrichment, alleging nonpayment for work performed on Mr. Koontz’s home based on an oral agreement. The work included an addition to the home and extensive renovations to the existing structure. The District Court rejected both claims, determining that there was no enforceable oral contract between the parties and that Summit did not sufficiently prove its damages for the unjust enrichment claim.The District Court found that the parties had not mutually agreed to sufficiently definite terms for an oral contract. The court noted that the project progressed without a clear understanding of the scope of work, how it would be paid for, and who would be responsible for payment. The court also found that Summit's invoices did not clearly define the terms of the contract. Furthermore, the court concluded that Summit had failed to prove the amount by which Mr. Koontz was unjustly enriched, i.e., its damages.Upon appeal, the Supreme Court of Wyoming affirmed the District Court's decision. The Supreme Court agreed that Summit had failed to show the existence of an enforceable oral contract with either Mr. Koontz or Ms. Kennette. The court also agreed with the lower court's finding that Summit had failed to establish its damages to a reasonable degree of certainty, which is necessary for an unjust enrichment claim. View "Summit Construction v. Koontz" on Justia Law

This case involves a divorce dispute between Randall Thomas Bailey and Sara Elizabeth Bailey, now known as Ms. Larson. The couple married in 2005 and have three minor children. Ms. Larson filed for divorce in December 2022. The main issues in the case revolve around the district court's decisions on child custody, child support, and property division.The district court granted joint legal custody of the children, with the children's primary residence set with Ms. Larson. The court also calculated child support, imputing income to Mr. Bailey, and divided the couple's property, which was valued at approximately $2.2 million. The division required an equalization payment of $475,000 from Mr. Bailey to Ms. Larson.Mr. Bailey appealed the district court's decisions, arguing that the court abused its discretion in determining custody, calculating child support, and dividing the parties' property. He also contested the valuation of his gun collection, the valuation of accounts at the date of separation, and whether two properties in South Carolina should have been included in the marital estate.The Supreme Court of Wyoming affirmed the district court's decisions. The court found that the district court did not abuse its discretion in deciding the issues of custody, child support, and property division. The court also found that the evidence presented supported the district court's findings and conclusions, and that the property division was not so unfair or unreasonable as to shock the conscience. View "Bailey v. Bailey" on Justia Law

The case revolves around a dispute between Sharon Ann Koch, a member of the Buffalo Trail Ranch subdivision, and Melissa R. Gray, who was purchasing a tract in the subdivision. Koch, along with other members and the developer of the subdivision, Rocky Mountain Timberlands, Inc. (RMT), sued Gray for allegedly violating the subdivision's restrictive covenants by placing garbage, junk, and other prohibited items on her property. The covenants, filed by RMT in 2008, also required the formation of a road maintenance association, which was never established.The District Court of Albany County dismissed all claims against Gray, applying the contractual "first to breach" doctrine. The court reasoned that RMT, by failing to form the road maintenance association, was the first to breach the covenants. Therefore, it was impossible to hold Gray to the covenants. Koch appealed this decision, arguing that she had no contractual relationship with Gray, and thus the "first to breach" doctrine should not apply to her claim.The Supreme Court of Wyoming agreed with Koch. It found that the "first to breach" doctrine, which is based on a contractual relationship, could not be applied as there was no contract between Koch and Gray. The court also rejected the lower court's conclusion that RMT's breach of the covenants rendered them inapplicable to Gray. The court found no legal basis for applying the "first to breach" doctrine to a third party's enforcement of covenants. Consequently, the Supreme Court reversed the lower court's decision and remanded the case for further proceedings. View "Koch v. Gray" on Justia Law

Forrest “Timber” Tuckness filed a quiet title action against the Town of Meeteetse, claiming adverse possession of Lot 5, a property adjacent to his own. Tuckness had been storing personal items on Lot 5 without permission since 1999. The property was purchased by Vision Quest Estates in 2003, and its president, Steve Christiansen, testified that he gave Tuckness permission to continue using the lot between 2005 and 2007. Tuckness denied this claim. In 2013, Vision Quest sold the lot to the Town of Meeteetse, despite Tuckness's claim of adverse possession. The Town erected a fence and gate on the lot and initiated a forcible entry and detainer action when Tuckness did not remove his property.The district court ruled in favor of the Town, finding that Tuckness had not met his burden of proof for adverse possession. The court found that Tuckness's use of the lot was actual, exclusive, open, notorious, and continuous from 1999 to 2013. However, the court also found that Christiansen's testimony that he had given Tuckness permission to use the lot was credible, which undermined the 'hostile' element of the adverse possession claim.In the Supreme Court of Wyoming, the court affirmed the district court's decision. The Supreme Court found that the district court did not err in concluding that Tuckness's adverse possession claim must fail because his use of Lot 5 was not hostile. The court found Christiansen's account of granting Tuckness permission to use Lot 5 credible, and therefore dismissed Tuckness's adverse possession claim with prejudice. View "Tuckness v. The Town of Meeteetse" on Justia Law

A group of residents from the Rafter J Ranch Subdivision in Teton County, Wyoming, appealed the Teton County Board of County Commissioners' approval of a petition by Stage Stop, Inc. to amend the Rafter J Planned Unit Development (PUD) to allow the use of Lot 333 for workforce apartments. The residents, referred to as Objectors, argued that the Board's decision was subject to judicial review, that the Board erred by allowing the PUD Amendment without requiring a vacation of the Rafter J Subdivision Plat, and that the Board's approval of the PUD Amendment was arbitrary, capricious, and not in accordance with the law.The District Court of Teton County affirmed the Board's decision. The Objectors then appealed to the Supreme Court of Wyoming. The Objectors argued that the Board's decision was a legislative act and therefore not subject to judicial review. They also claimed that the Board did not follow the proper procedure for amending the PUD and that the Board did not properly consider the requirement that the PUD Amendment comply with the underlying base zoning to the maximum extent practicable.The Supreme Court of Wyoming affirmed the lower court's decision. The court found that the Board's approval of the PUD Amendment was subject to judicial review to determine whether the Board followed its rules and regulations. The court also found that the Board properly considered Stage Stop's request to amend the PUD and that the Board's decision had no effect on any private contractual rights which the Objectors may have from the Plat restrictions. The court concluded that the Board followed the Land Development Regulations (LDRs) and made reasonable choices in approving the PUD Amendment. View "Brazinski v. Board of County Commissioners" on Justia Law

The case involves a dispute between the Teton County Assessor and Aspen S, LLC along with the Kelvin and Nancy Stirn Trusts. The landowners in Teton County contested the reclassification of their property from "agricultural" to "non-agricultural" by the Teton County Assessor. The Teton County Board of Equalization held a contested case hearing and found that the County Assessor's removal of the agricultural classification was incorrect. The County Assessor then appealed this decision to the State Board of Equalization.The State Board of Equalization consolidated the cases and sided with the County Assessor, stating that the County Board of Equalization had rejected the Assessor's determination without sufficient explanation. However, the State Board also assessed all the evidence independently and found that the taxpayers had not met their burden of proof. The landowners then sought judicial review of the agency's action in the district court, a portion of whose decision was adverse to the Teton County Assessor who now seeks further judicial review in the Supreme Court of Wyoming.The Supreme Court of Wyoming reversed and remanded the case, finding that the County Board of Equalization's decision lacked necessary findings of fact and conclusions of law as required by the Wyoming Administrative Procedure Act (WAPA). This lack of necessary findings and conclusions rendered the record insufficient for judicial review, causing the County Board of Equalization to act arbitrarily and capriciously. The case was remanded to the district court, with instructions to remand to the State Board of Equalization, which was instructed to remand to the Teton County Board of Equalization for findings and conclusions as required by WAPA. View "Teton County Assessor v. Aspen S, Llc" on Justia Law

In this case, the City of Laramie, Wyoming, sued the University of Wyoming and its Board of Trustees, challenging the drilling and operation of certain water wells. The city argued that the university was in violation of a 1965 deed covenant prohibiting the drilling of one of the wells and was also in violation of a city ordinance. The city also claimed that legislation exempting the university from this city ordinance was unconstitutional. The district court dismissed some of the city's claims and granted summary judgment in favor of the university on the remaining claims. The Supreme Court of Wyoming affirmed the lower court's decision. The court held that the university was protected by sovereign immunity from the city's attempts to enforce the deed covenant. It also held that the state law exempting the university from the city ordinance was constitutional. The court further noted that the law precluded the city from enforcing its ordinance against the university. View "City of Laramie, Wyoming v. University of Wyoming" on Justia Law

In Wyoming, Darrell R. Turcato and Robbin D. Wilkins (Appellants) and Jan Frady and Larry Turcato (Petitioners) were beneficiaries of two trusts created by their parents. The Appellants sought to appeal the district court's decision that a warranty deed executed by the Trusts transferring property to them was invalid due to a defective acknowledgment. The property in question was a house, which was held 50% by the JT Trust and 50% by the VT Trust. The mother, Virginia Turcato, decided to transfer the house to the Appellants in recognition of their assistance. However, her signature was notarized outside her presence. After her death, the Petitioners sought a declaration that the transfer was invalid due to the defective acknowledgment. The district court determined that the Petitioners, as beneficiaries of the trusts, had an interest in the property when the deed was executed and therefore declared the warranty deed void against them.The Wyoming Supreme Court reversed the district court's decision. The Court held that a defective acknowledgment does not render a warranty deed void ab initio under Wyoming law. It found that when the parties signed the Warranty Deed, title immediately passed to Appellants, and that title was valid against all but certain parties. The Court also held that the Petitioners did not have an interest in the property at the time of the transfer and therefore had no standing to challenge the Warranty Deed. The Court concluded that the Warranty Deed is valid between the Trusts and the Appellants, and remanded the case to the district court for dismissal. View "Turcato v. Frady" on Justia Law

In the State of Wyoming, the Supreme Court examined a dispute between Tony R. Testolin, Tim Karlberg, and Thirty-One Bar Ranch Company about the use of an access easement. The defendants (Testolin and Karlberg) owned an easement that passed over a portion of Thirty-One Bar's property. Thirty-One Bar challenged the validity of the easement and its use. While the district court affirmed the validity of the easement, it restricted how the defendants could use it. The court ruled that the defendants could not use the easement to allow a commercial hunting outfitter access to their property, which the defendants appealed.The Supreme Court of Wyoming reversed the lower court's decision. It ruled that the easement's language did not restrict the defendants from using it to allow a hunting outfitter access to their property. The court also ruled that Thirty-One Bar did not meet its burden of proving that such use of the easement materially increased the burden on their property. Thus, the lower court erred in declaring this use of the easement as impermissible. The court emphasized that an easement may be used for any reasonable use of the dominant estate, provided that use does not materially increase the burden on the servient estate. View "Testolinv. Thirty-One Bar Ranch Company" on Justia Law

The Supreme Court reversed the order of the district court denying the State's civil in rem action for forfeiture of $75,000 in United States currency seized by law enforcement officers from Lorenzo Gallaga, holding that the district court erred in applying Wyoming's forfeiture and controlled substances laws.In denying the State's action for forfeiture, the district court concluded that the State failed to meet its burden of showing that Gallaga's presence in Wyoming with the $75,000 was an act in furtherance of a conspiracy to facilitate a violation of the Wyoming Controlled Substances Act. The Supreme Court reversed, holding that the district court erred in denying the State's civil forfeiture claim because the State met its burden of proving that the currency seized from Gallaga was traceable to the exchange of controlled substances or otherwise used to facilitate activities which, if undertaken, would violate the Act. View "State v. Gallaga" on Justia Law