Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to dismiss the State's complaint seeking the forfeiture of currency the State seized from him, holding that the district court had subject matter jurisdiction over the State's forfeiture complaint.In his motion to dismiss, Appellant asserted that the circuit court had exclusive jurisdiction over the action because the amount of currency seized was less than $50,000. The district court denied the motion, finding that Wyo. Stat. 35-7-1049, the forfeiture statute, vested exclusive jurisdiction in district courts. The Supreme Court affirmed on different grounds, holding (1) the forfeiture statute does not grant exclusive jurisdiction over forfeiture actions to district courts; and (2) district courts have general jurisdiction over civil forfeiture proceedings. View "Orosco v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that the lease of property in this case did not violate Appellants' first refusal to purchase the property, holding that the district court did not err.John and Melanie Lennon leased property owned by the Larry Lee Luckinbill Living Trust for a 125-year term. Thereafter, Appellants - Anne Holding and the Crandall Creek Ranch Company - brought suit against the Lennons and the trust's trustee, seeking a declaratory judgment stating that the lease violated their right of first refusal. The district court concluded that the right of first refusal remained in effect but that the lease did not trigger that right. The Supreme Court affirmed, holding that the lease did not trigger Appellants' right of first refusal. View "Holding v. Luckinbill" on Justia Law

In this property dispute, the Supreme Court reversed in part the judgment of the district court granting summary judgment to the Hogback Ranches Property Owners Improvement and Service District (HRISD) on the issue of whether HRISD violated the Hoback Ranches subdivision's protective covenants by installing wire fencing around the subdivision's perimeter and otherwise affirmed, holding that the district court erred in part.Plaintiffs, who resided in the subdivision, brought suit against HRISD and their neighbor, Michael Jerup, alleging, inter alia, that HRISD violated the subdivision’s protective covenants with its perimeter fence and that Jerup violated the covenants by conducting commercial activity on his property. HRISD and Jerup counterclaimed, alleging that Plaintiffs violated the protective covenants by installing wood posts set in concrete. The district court (1) granted summary judgment to HRISD on Plaintiffs' claims; (2) granted summary judgment to HRISD and Jerup on their counterclaim; and (3) entered judgment for Jerup on Plaintiffs' claim. The Supreme Court reversed the district court's summary judgment to HRISD on the perimeter fence issue and otherwise affirmed, holding that the district court erred in deciding that a buck and pole fence covenant did not apply to the subdivision's perimeter fence. View "Winney v. Hoback Ranches Property Owners Improvement & Service District" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment in favor of Security State Bank (SSB) and dismissing Plaintiff's complaint asserting a first priority equitable lien on certain ranch property, holding that the district court did not err.Plaintiff loaned his friends, the Waymans, $100,000 to make a down payment on a ranch. After the Waymans defaulted on their mortgage the lender, SSB, sold the property at a foreclosure sale. In an effort to recover the $100,000 down payment, Plaintiff sued SSB, asserting a first priority equitable lien on the ranch property. The district court granted summary judgment for SSB. The Supreme Court affirmed, holding that the district court (1) did not erroneously convert SSB's motion to dismiss into a motion for summary judgment; and (2) did not err when it determined that there was no genuine issue of material fact regarding SSB's superior priority mortgage on the ranch property. View "Martin v. Security State Bank" on Justia Law

The Supreme Court affirmed the judgment of the district court clarifying an order it entered in 2017 dividing the Aimone Ranch into two parcels, holding that the district court properly clarified its 2017 order under Wyo. R. Civ. P. 60(a) and denied Rex Snyder's remaining claims.As part of Rex and Ronda Snyder's divorce proceedings, the district court divided the Aimone Ranch into two parcels. The order, however, did not specify the dividing line between the parcels, nor did it address fencing. In 2019, Rex built a fence to separate the parcels, and Ronda refused to pay half the fencing costs. Rex filed a motion seeking to enforce the 2017 order and requesting that the court order Ronda to accept a quit claim deed for her parcel as fenced, accept an easement over his parcel, and reimburse him for half the fencing costs. The district court clarified its 2017 order and denied Rex's remaining claims. The Supreme Court affirmed, holding that there was no error. View "Snyder v. Snyder" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendant Gerald James on his quiet title claim and granting both Defendants summary judgment on Plaintiffs' remaining claims, holding that summary judgment was properly granted.Plaintiffs, Robert and Naomi James, filed a complaint asserting multiple claims against Defendants, Gladys Winkel and Gerald, including a claim to quiet title to real property. Gerald answered and filed several counterclaims. Winkel answered separately and also filed a counterclaim. The district court granted summary judgment generally in favor of Defendants. The Supreme Court affirmed, holding (1) the district court did not err in ruling that Plaintiffs could not maintain a claim for equitable conversion because they failed to timely plead it; and (2) genuine issues of material fact did not preclude the grant of summary judgment to Defendants on Plaintiffs' claims. View "James v. Winkel" on Justia Law

The Supreme Court reversed the judgment of the district court striking a lien filed by Excel Concrete & Excavation, LLC against Douglas Schrier's Teton County property, holding that the expedited and limited proceeding authorized by Wyo. Stat. Ann. 29-1-601(b) afforded Schrier no relief.After Schrier hired Excel to provide construction services on his property a dispute arose over payments. Excel eventually filed a lien against Schrier's property. Schrier filed a petition to strike the lien pursuant to section 29-1-601(b), asserting that the lien was grounds because Excel's preliminary lien notice was untimely and because the lien contained material misstatements. The district court struck the lien, concluding that Excel's preliminary lien notice was untimely. The Supreme Court reversed, holding that Schrier's claim was insufficient to warrant relief under s. ection 29-1601(b). View "Douglas Matthew Schrier Living Trust v. Excel Concrete & Excavation, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court deciding that Plaintiffs failed to establish the elements required to establish an implied easement, holding that the district court did not err.Plaintiffs sued Defendant, their neighbor, for quiet title and a declaratory judgment that they had an implied easement across Defendant's property for commercial recreational activities. The district court concluded that Plaintiffs did not have an implied easement across Defendant's property because they failed to carry their burden to prove the claimed easement was necessary and beneficial to the enjoyment of their property. The Supreme Court affirmed, holding that the district court (1) applied the correct "necessity" standard to establish an implied easement; and (2) did not find that Defendant was a bona fide purchaser entitled to statutory and common law protections. View "Wheeldon v. Elk Feed Grounds House, LLC" on Justia Law

In this eminent domain dispute, the Supreme Court reversed the first order of the district court allowing EME Wyoming, LLC access to approximately 52,000 acres of land located primarily in Goshen County and affirmed the second order permanently barring EME from using survey information it collected to file permits to drill (APD) with the Wyoming Oil and Gas Conservation Commission (WOGCC), holding that the district court erred in part.EME sought access to land owned by four limited liability companies (collectively, the BRW Group) for the purpose of gathering data to evaluate the property's suitability for condemnation. The BRW Group denied EME's request, believing that EME sought access to the lands solely to collect data with which to file APDs, which is not a proper purpose under the Wyoming Eminent Domain Act. The district court allowed EME to access the property to survey and gather data but restricted it from using the survey information to file APDs. The Supreme Court reversed in part, holding (1) EME should not have been permitted access to the property because it did not make the required showing for access to the BRW Group's property; and (2) therefore, the data EME collected to file APDs was not lawfully in EME's possession, and EME could not use the data for any purpose. View "BRW East, LLC v. EME Wyoming, LLC" on Justia Law

The Supreme Court reversed the decision of the district court denying Plaintiff attorney fees and costs after dismissing this declaratory judgment action as moot, holding that the court erred in concluding that Plaintiff was not entitled to his attorney fees and costs.Plaintiff brought a declaratory judgment action asking the district court to declare that he had the right to install underground fiber optic cable within a utility easement located on Defendants' property. Defendants subsequently moved for judgment on the pleadings, claiming that Defendant had the right to install the fiber optic cable within the easement and that the case was now moot because there was no longer a justiciable controversy. The district court agreed, dismissed the action, and denied attorney fees and costs. The Supreme Court reversed, holding that Plaintiff was entitled to his attorney fees and costs under the easement's fee-shifting provision. View "Levy v. Aspen S, LLC" on Justia Law