Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the district court declaring that Scott Smithson and Elena Morozova (the Smithsons) did not have the right to fish in the Little Laramie River, holding that a 1965 warranty deed granted a profit that was appurtenant to the Smithson tract, giving the Smithsons the right to access to fish in the Little Laramie River.The predecessors of Frederick and Stephanie Lindzey conveyed the right to fish in the Little Laramie River to the predecessors of the Smithsons. The Smithsons filed suit for declaratory judgment and an injunction preventing the Lindzeys from interfering with it, arguing that they continue to hold the right to fish because it is a servitude appurtenant to the land. The district court found in favor of the Lindzeys, declaring that any right to fish was a license that ended when the original grantees sold their interest in the land. The Supreme Court reversed, holding that the plain language of the 1965 warranty deed created a profit, and nothing in the deed or in the context of the transfer overcame the presumption that the profit was appurtenant to the Smithson tract. View "Smithson v. Lindzey" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment for Plaintiff on his claim to quiet title in his window wells that encroached on Defendant's property based on adverse possession, holding that the district court did not err.Plaintiff filed a complaint requesting declaratory judgment that he was the owner of the disputed window wells by virtue of adverse possession, a decree quieting title in his name, and a preliminary injunction preventing Defendant from removing the window wells or otherwise damaging his home. The district court granted summary judgment for Plaintiff, finding that Plaintiff met his burden of making a prima facie showing of adverse possession. The Supreme Court affirmed, holding (1) Plaintiff made a prima facie claim for adverse possession of the window wells, and Defendant failed to show a disputed issue of material fact; and (2) the district court did not commit procedural errors that prejudiced Defendant and properly granted summary judgment in favor of Plaintiff. View "Woodward v. Valvoda" on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of Saratoga Inn Overlook Homeowners Association, Inc. (HOA2) on its claim for breach of fiduciary duty and awarding punitive damages, holding that the district court did not abuse its discretion.In developing the Saratoga Inn Overlook Subdivision, Orion Point LLC, whose sole members were Cynthia Bloomquist and Chris Shannon, established the Saratoga Inn Overlook Homeowners Association, Inc. (HOA1). When HOA1 was dissolved, Bloomquist unilaterally formed HOA2. Bloomquist then sold Orion Point's lots in the subdivision and conveyed the common area to Prancing Antelope I, LLC. HOA2 brought this action against Bloomquist, Shannon, and Prancing Antelope, asserting several claims. The district court granted summary judgment for HOA2 on its claim for ejectment. The Supreme Court affirmed, holding (1) HOA2 was entitled to summary judgment on its ejectment claim; (2) Wyo. R. Civ. P. 19 did not require the joinder of members of HOA1; and (3) the district court did not abuse its discretion when it awarded attorneys' fees as punitive damages. View "Prancing Antelope I, LLC v. Saratoga Inn Overlook Homeowners Association, Inc." on Justia Law

In this property dispute, the Supreme Court reversed the judgment of the district court finding largely in favor of Larry Wagoner, holding that the oral contract between the parties in this case was void.Donald Fuger and Wagoner entered into an oral agreement to construct two buildings on a portion of the Fugers' property. When the buildings were completed Wagoner occupied one and rented the other for several years. Fuger and wife later sued Wagoner and his wife seeking to evict them from the property. Wagoner, in turn, sued the Fugers, alleging contract and equitable theories for ownership of one building and the underlying property. The district court held that an enforceable oral contract existed between Fuger and Wagoner and awarded Wagoner $302,234 plus post-judgment interest. The court did not reach Wagoner's equitable claims. The Supreme Court reversed, holding that the district court erred in finding that a valid oral contract between Wagoner and Fuger existed. The Court remanded for consideration of Wagoner's equitable claims. View "Fuger v. Wagoner" on Justia Law

The Supreme Court summarily affirmed the judgments of the district court in favor of Plaintiff on his two complaints seeking to be declared the sole owner of certain real properties and to invalidate certain documents in the properties' chains of title, holding that Defendant's pro se briefs failed to comply with the Wyoming Rules of Appellate Procedure.In each case, Plaintiff filed a motion for summary judgment, and Defendant did not respond to the motions. The district court granted Plaintiff's motions and entered judgments declaring him to be the sole owner of the properties and invalidating the documents at issue. Defendant appealed, raising seven issues in his pro se briefs. The Supreme Court summarily affirmed the district court's judgments, holding that Defendant's pro se briefs did not provide any cogent argument and otherwise failed to comply with the rules of appellate procedure. View "Corrigan v. Vig" on Justia Law