Justia Wyoming Supreme Court Opinion Summaries

Articles Posted in Real Estate & Property Law
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The Supreme Court dismissed in part and reversed in part the orders of the probate court and district court in these probate and partition matters, holding that remand was required.Dwight and Betty Lyman, as Trustees of their living trust (Lyman Trust), owned a parcel of property as tenants in common with George Fisher and another parcel in common with George's deceased parents. George sold his parents' interests in the two parcels to the Childs Trust. Lyman Trust filed a petition in the district court seeking to partition the parcels and filed a motion in the probate court seeking to set aside the sale. The probate court denied the motion, and the district court dismissed the partition petition without prejudice for failure to join Childs Trust as a required party. The Supreme Court (1) dismissed Lyman Trust's appeal of the probate court's actions, holding that Lyman Trust lacked standing in the Fisher probate action; and (2) reversed the district court's judgment dismissing Lyman Trust's partition action, holding that the court erred by dismissing the action rather than ordering the joinder of Childs Trust, and dismissal was not harmless. View "Lyman v. Fisher" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Felix Felicis, LLC's (Felix) application to vacate an arbitrator award in favor of Riva Ridge Owners Association (RROA) in this dispute over annual assessments, holding that the district court did not err in denying the application.This litigation arose after RROA's site committee rejected Felix's plans to build a home on its tract in the Riva Ridge subdivision. The attorney fees and costs RROA incurred during the litigation RROA ratably levied upon all tract owners in the subdivision via annual assessments. Felix refused to pay a portion of them based on its belief that RROA was not authorized by the restrictive covenants to assess attorney fees and costs against the tract owners. Felix later submitted its dispute with RROA to binding arbitration. The arbitrator granted summary judgment for RROA and awarded it a total of $334,890. Felix moved to vacate the arbitration award on the grounds that the arbitrator exceeded his powers by failing to consider Felix's affirmative defenses. The district court denied the application. The Supreme Court affirmed, holding that Felix failed to show by clear and convincing evidence that the arbitrator made a manifest mistake of the law in granting summary judgment for RROA. View "Felix Felicis, LLC v. Riva Ridge Owners Ass'n" on Justia Law

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The Supreme Court affirmed the judgment of the district court concluding that Plaintiffs did not adversely possess their northern neighbors deeded property in the Bighorn Mountains because their use was presumptively permissive, holding that the district court did not clearly err.Plaintiffs' fancy had enclosed portions of Defendant's deeded property within Plaintiffs' property since the 1950s. Plaintiffs brought this suit requesting that the district court quiet title in the disputed lands. The district court concluded that the fence was built for convenience, and therefore, Plaintiffs failed to meet their burden of actual notice to Defendant of their hostile use of the land. The Supreme Court affirmed the district court's decision quieting title in Defendant and ejecting Plaintiffs from the property, holding that Plaintiffs were not entitled to relief on their allegations of error. View "Lyman v. Childs" on Justia Law

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The Supreme Court reversed the judgment of the district court dismissing this action brought by Sweetwater Station, LLC (Sweetwater) against the Sweetwater Station Homeowners Association (HOA) in this dispute over the covenants, conditions, and restrictions (CCRs) applicable to the subdivision Sweetwater Station Addition, holding that the district court erred in dismissing Sweetwater's claims.In 2020, the HOA unilaterally recorded an amendment to the CCRs that affected the rights of the declarant, Sweetwater. Sweetwater sued the HOA and its members, seeking a declaration that the amendment was invalid and also asserting claims for quiet title, slander of title, and interference with a prospective contract. The district court dismissed the complaint for failure to state a claim after finding that the amendment to the CCRs was valid. The Supreme Court reversed, holding (1) the district court erred in dismissing Sweetwater's declaratory judgment and quiet title claims because the amendment provisions of the CCRs were ambiguous, requiring extrinsic evidence to determine the parties' intent; and (2) Sweetwater adequately pled its claims for slander of title and interference with a prospective contract. View "Sweetwater Station, LLC v. Pedri" on Justia Law

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The Supreme Court affirmed the decision of the district court granting summary judgment to Plaintiff on his claim of adverse possession of one-tenth of an acre of Defendants' property, holding that the district court did not err or abuse its discretion.On appeal, Defendants argued that Plaintiff could not show adverse possession because there was a factual question as to whether Plaintiff's use of the property was permissive under the theory of neighborly accommodation. The Supreme Court disagreed and affirmed, holding (1) Plaintiff established a prima facie claim of adverse possession which Defendants failed to rebut; and (2) there was no genuine issue of material fact, and the district court did not err in granting summary judgment to Plaintiff. View "Kudar v. Morgan" on Justia Law

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The Supreme Court affirmed the decision of the district court in favor of Plaintiff on its action for declaratory judgment and quiet title, concluding that a right-of-way and access easement over a twenty-foot-wide strip of property connecting a public road to land now owned by Plaintiff was appurtenant and continued to benefit Plaintiff, holding that there was no error.Defendant's predecessor granted a right-of-way and access easement over the property at issue, but Defendant denied Plaintiff access across the easement, claiming that the easement was in gross and provided access only to Plaintiff's predecessor in interest. The district court granted summary judgment in favor of Plaintiff. The Supreme Court affirmed, holding that the evidence was insufficient to overcome the presumption of appurtenance. View "Upper Wagon Box, LLC v. Box Hanging Three Ranch Ltd. Partnership" on Justia Law

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The Supreme Court affirmed the decision of the district court entering judgment in favor of the Town of Dubois and dismissing Plaintiff's declaratory judgment action against the Town seeking to reclaim 30.17 acres of real property, holding that there was no error in the proceedings below.Plaintiff sought to reclaim property that the Town previously attempted to condemn but ultimately acquired through a settlement agreement with Plaintiff. The district court granted summary judgment in favor of the Town. The Supreme Court affirmed, holding (1) the settlement agreement satisfied, as a matter of law, the three elements of waiver and did not contravene the public policy behind the Wyoming Eminent Domain Act; and (2) therefore, the Town was entitled to judgment as a matter of law. View "Colton v. Town of Dubois" on Justia Law

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The Supreme Court affirmed the judgment of the district court granting partial summary judgment to the Estate of Gale Iverson (the Estate) on its real property claims against Cherie Davidson-Eaton (Eaton), Mr. Iverson's caregiver, and ordering Eaton to, among other things, provide the Estate with an accounting, holding that there was no error.The Estate filed an action for an accounting and sought to recover property it alleged Eaton unlawfully transferred to herself. In response, Eaton filed a creditor's claim against the Estate, alleging that she had a right to compensation for services she rendered to Mr. Iverson while he was living. The district court consolidated the lawsuits, granted partial summary judgment to the Estate on its real property claims, denied Eaton's claims, found the Estate was entitled to lost rents and profits, and ordered Eaton to provide the Estate with an accounting. The Supreme Court affirmed, holding that the district court did not abuse its discretion or act contrary to law. View "Davidson-Eaton v. Iversen" on Justia Law

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The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claims for unjust enrichment, constructive trust, and quiet title, holding that the district court did not err in granting summary judgment to Defendant on all three claims.Plaintiff, Defendant's mother, brought this suit seeking to quiet title to a parcel of property that Defendant acquired when he exchanged it for a parcel of property that his parents deeded to him years earlier. The district court granted summary judgment to Defendant on Plaintiff's claims for unjust enrichment, constructive trust, and quiet title. The Supreme Court affirmed, holding that the right to bring a quiet title action belonged to Defendant, not Plaintiff. View "Statzer v. Statzer" on Justia Law

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The Supreme Court reversed the judgment of the district court ruling that North Silo Resources, LLC, the mineral lessee in this case, did not have standing to quiet title or to claim breach of its lease and that North Silo's mineral lease encumbered fifty percent of the mineral estate, holding that the district court erred as to both issues.North Silo brought an action seeking a declaratory judgment and to quiet title in certain minerals underlying property located in Laramie County and bringing a breach of lease claim against the mineral owner. The district court concluded (1) North Silo did not have standing to quiet title or to claim breach of its lease; and (2) North Silo's mineral lease encumbered only fifty percent of the mineral estate. The Supreme Court reversed, holding (1) North Silo had standing to quiet title and to assert a claim for breach of lease; and (2) North Silo's lease encumbered 100 percent of the mineral estate. View "North Silo Resources, LLC v. Deselms" on Justia Law