Justia Wyoming Supreme Court Opinion Summaries

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

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

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

The Supreme Court affirmed the judgment of the district court affirming the decision of the Wyoming State Board of Equalization (Board) affirming the tax assessment set forth by the Wyoming Department of Revenue (DOR) imposing severance and ad valorem property taxes on the waste mine gas (WMG) captured and used by Solvay Chemicals, Inc., holding that there was no error.Solvay used the WMG released from its trona mining operations to help fuel its soda ash processing plant during the years 2012 through 2015. The DOR imposed severance and ad valorem taxes on the WMG during those years. Solvay objected, arguing that the WMG was not taxable under the severance or ad valorem tax statutes. The Supreme Court affirmed, holding that Solvay failed to show the DOA and DOR improperly valued the WMG for production years 2012-2015. View "Solvay Chemicals, Inc. v. Wyoming Dep't of Revenue" on Justia Law

The Supreme Court affirmed the judgment the district court denying TEP Rocky Mountain LLC's (TEP RM) motion to dismiss this action, granting summary judgment to Record TJ Ranch Limited Partnership (TJ Ranch) on several issues, and ruling that TEP RM had breached the parties' agreements, holding that there was no error.TJ Ranch brought this action seeking payment under a surface use and damage agreement governing oil and gas development and production of ranch lands. TEP RM filed a motion to dismiss for lack of personal jurisdiction, which the district court denied. The court ultimately concluded that TJ Ranch was entitled to payment. The Supreme Court affirmed, holding that the district court (1) correctly exercised personal jurisdiction over TEP RM; (2) did not clearly err in its findings; and (3) did not abuse its discretion in denying TEP RM's motions to stay. View "TEP Rocky Mountain LLC v. Record TJ Ranch Limited Partnership" on Justia Law

The Supreme Court affirmed the order of the district court affirming the judgment of the Board of County Commissioners of Park County approving Trial County Telephone Association, Inc.'s (TCT) application for a special use permit to construct a 150-foot broadband communications tower in Park County, holding that the Board did not arbitrarily or capriciously in approving the application.Specifically, the Supreme Court held (1) the Board had a rational basis to conclude that the proposed was not oversized, and therefore, the Board's approval of TCT's application did not violate Park County development regulations; and (2) the Park County regulations did not require the Board to consider alternative sites for a project before approving a special use permit, and it therefore did not act arbitrarily or capriciously in approving the application without considering alternative locations for the proposed tower. View "Jolovich v. Board of County Commissioners of Park County" on Justia Law

The Supreme Court affirmed the order of the district court denying Robert Gill's motion to enforce a judgment confirming arbitration awards entered against Elizabeth Lockhart, holding that there was no error in the proceedings below.Siblings Robert Gill and Lockhart were the beneficiaries of a trust that owned land in Teton County. The trust decided to use the land to create a subdivision. This case concerned an arbitration award contained in an order covering the parties' rights and obligations regarding the subdivision. Gill successfully filed a petition asking the district court to confirm two of the arbitration awards. Thereafter, Gill filed his motion to enforce the judgment. The district court denied the motion, finding that Gill failed to prove some of his damages. The Supreme Court affirmed, holding that the district court did not abuse its discretion by not allowing Defendant to present certain evidence either at the evidentiary hearing or after the district court announced its oral ruling. View "Gill v. Lockhart" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that pursuant to the doctrine of merger, the parties in this case held certain property as joint tenants with rights of survivorship, holding that the district court reached the correct result.Julie Ann Bell and her longterm romantic partner, Patrick Dominick, owned property together. After Bell died, the executor for her estate brought this action claiming that the parties held the property as tenants in common. Dominick answered, alleging that he and Bell took title as joint tenants with rights of survivorship. The district court granted judgment in favor of Dominick. The Supreme Court affirmed, holding that the district court correctly held that Bell and Dominick held the property as joint tenants with rights of survivorship. View "CIBC National Trust Co. v. Dominick" on Justia Law

The Supreme Court affirmed the judgment of the district court in this dispute about who owned an undeveloped .53-acre parcel in Teton Village and whether it should be sold or conserved, holding that there was no reversible error.Many different parties in this case asserted different ownership theories as to the parcel at issue, depending on which entity they claimed to derive their interest from. The district court had issued several summary judgment orders and related rulings, which the Supreme Court affirmed. At issue in these cross-appeals was whether the receivership order pertaining to a 2006 LLC was an appealable order. The Supreme Court affirmed, holding (1) laches barred Tram Tower Townhouse Association's claim that a 1998 conveyance was unlawful, and therefore, the Association could not challenge the later-issued receivership order; and (2) the district court did not abuse its discretion by failing to order the receiver to maintain the 2006 LLC as a going concern. View "Dvorson v. Weiner" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Appellants' petition for review of a decision of the Board of County Commissioners, Lincoln County under Wyo. R. App. P. 12 and Wyo. Stat. Ann. 16-3-114, holding that the district court abused its discretion by sanctioning Appellants with dismissal of their petition for review.The district court dismissed Appellants' petition, determining that Wyo. R. App. P. 2.06 required a transcript to be filed within sixty days of the filing of the petition for review of agency action and that no transcript was filed. The Supreme Court reversed, holding (1) the district court misstated and misapplied Rule 2.06; (2) the Board failed to transmit the record as required by Rule 12.07; and (3) because the Board, not Appellants, had the responsibility to transmit the entire record to the district court, the court abused its discretion by dismissing the action. View "Depiero v. Board of County Commissioners, Lincoln County" on Justia Law