Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing EOG Resources, Inc.'s complaint under the Wyoming Eminent Domain Act seeking to condemn a seventy-acre pipeline easement on the grounds that EOG had not complied with the Act's good-faith negotiation requirement, holding that, under the facts and circumstances of this case, EOG did not satisfy the good-faith negotiation requirement.After conducting oil and gas operations on the Floyd C. Reno & Sons, Inc.'s (Reno) ranch pursuant to a surface use agreement, EOG proposed an amended surface use agreement that would grant it additional rights over the property. Reno rejected EOG's offer. Thereafter, EOG filed an amended complaint seeking to condemn seventy acres. The district court held that EOG failed to satisfy the Act's good-faith negotiation requirement and dismissed the complaint. The Supreme Court affirmed, holding (1) there must be a sufficient resemblance to the property sought to be condemned and the property described in the offer to allow a court to conclude that the subject of the negotiation was clear to both parties and that the offer might have been accepted as it related to the property ultimately sought to be condemned; and (2) the record supported the conclusion that EOG failed to meet that standard. View "EOG Resources, Inc. v. Floyd C. Reno & Sons, Inc." on Justia Law

In this dispute over an accessway traversing Patricia Douglas' property the Supreme Court affirmed the decision of the district court holding that the accessway was a driveway subject to a conservation easement's development limitation, holding that the district court did not err.Jackson Hole Land Trust (JHLT) held the conversation easement, which limited the area that could be developed on Douglas' property. Douglas sought a declaration that the accessway crossing her property was a road rather than a driveway and thus should not be counted toward the total developed area. The district court granted summary judgment in favor of JHLT but declined to award it costs and attorneys' fees. The Supreme Court affirmed, holding (1) the accessway traversing Douglas' property is a driveway subject to the conservation easement's site development limitation; and (2) the easement terms do not provide for the award of costs and attorneys' fees for a declaratory judgment action. View "Jackson Hole Land Trust v. Douglas" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Tiphany L. Gayhart, trustee of the Tiphany L. Gayhart Living Trust, did not have an easement over Teala Drive, a private road in a subdivision, holding that the district court did not err in finding that Gayhart did not have a valid easement.Specifically, the Supreme Court held that the language of the easement and the declaration of covenants, conditions and restrictions for the subdivision demonstrated that the easement over Teala Drive was to benefit the subdivision, not property outside the subdivision. Because Gayhart's property lay outside the subdivision, the easement was not appurtenant to her property and could not be transferred apart from the subdivision. View "Gayhart v. Corsi" on Justia Law

In this real property dispute, the Supreme Court dismissed Appellant's appeal from the district court's partial summary judgment order, holding that the district court abused its discretion when it certified its partial summary judgment order as a final judgment under Wyo. R. Civ. P. 54(b).After his long-term romantic partner died, Defendant provided notice that he was the surviving joint tenant with survivorship rights as to a home in Teton County. Plaintiff, the executor of the decedent's estate, filed a declaratory judgment that Appellant and the decedent were tenants in common and asserted claims for breach of contract or partition. The district court concluded that Defendant owned the property as the surviving joint tenant. Over Defendant's objection, the district court certified the partial summary judgment order as a final judgment and stayed the remaining claim for slander of title. Plaintiff appealed. The Supreme Court dismissed the appeal and declined to convert the appeal to a writ of review, holding that the district court abused its discretion in finding "no just reason for delay" and certifying its partial summary judgment order as a final judgment. View "CIBC National Trust Co. v. Dominick" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Buyer had breached a contract for the sale of a lot in a subdivision and ordering Buyer to specifically perform, holding that the district court did not abuse its discretion when it ordered Buyer to specifically perform.After Buyer entered into a contract with Seller for the sale of the lot Buyer decided he no longer wanted to purchase the lot. Seller filed this lawsuit asserting breach of contract and seeking specific performance. Buyer argued that the contract was unenforceable for failing to comply with the statute of frauds. The district court disagreed and entered judgment in favor of Seller, ordering Buyer to specifically perform the contract. The Supreme Court affirmed, holding (1) while the contract failed to comply with the statute of frauds, it was enforceable under the doctrine of partial performance; and (2) the district court did not abuse its discretion when it ordered Buyer to specifically perform. View "Davis v. Harmony Development, LLC" on Justia Law

The Supreme Court reversed the judgment of the district court forfeiting $470,040 in United States currency seized from Robert Miller to the State under the Wyoming Controlled Substances Act, Wyo. Stat. Ann. 35-7-1001 to -1060, holding that the State unreasonably delayed filing the action.Miller filed a motion to dismiss the case on grounds that the State's 270-day delay in instituting proceedings violated the statutory requirement that the State institute such proceedings "promptly" and his due process rights under the United States Constitution. The district court denied the motion and forfeited the currency to the State. The Supreme Court applied the four-factor balancing test from Barker v. Wingo, 407 U.S. 514 (1972), to assess whether Miller's right to due process had been violated. The Court then reversed and remanded for dismissal with prejudice, holding that the State failed "promptly" to institute the forfeiture proceedings, in violation of section 35-7-1049(c) and Miller's right to due process under the federal Constitution. View "Miller v. State" on Justia Law

The Supreme Court reversed in part the judgment of the district court granting summary judgment in favor of Plaintiff on his adverse possession claim and in favor of Defendant on Plaintiff's prescriptive easement and implied easement claims, holding that material issues of fact precluded summary judgment in favor of Plaintiff on his adverse possession claim and this error hindered review of the prescriptive easement claim.At issue was the property boundary between two residential lots connected by a shared driveway. Plaintiff claimed that he had adversely possessed a thirty-inch strip of Defendant's driveway, that he had an easement over the entire driveway, and that Defendant had intentionally trespassed on the adversely possessed portion of his property. The district court granted summary judgment for Plaintiff on the adverse possession claim and granted summary judgment for Defendant on the prescriptive easement and implied easement claims. The Supreme Court reversed in part, holding (1) the court erred in granting summary judgment on the adverse possession claim because issues of material fact concerning hostility existed; (2) because the prescriptive easement cannot be resolved independent of the adverse possession claim, review on this claim was precluded; and (3) the district court did not err in granting summary judgment for Defendant on the implied easement claim. View "Hulme v. O'Hare" on Justia Law

In this case concerning a "race to permit" dispute between the parties in this case, both of whom held mineral interests in certain drilling and spacing units and both of whom wanted to be the "operator" of those units, the Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss for lack of subject matter jurisdiction, holding that the district court and not the Wyoming Oil and Gas Conservation Commission was the proper forum to resolve this case.Defendant won the race to permit and obtained operator status over the lands at issue. Plaintiff filed a complaint alleging that Defendant violated Wyo. Stat. Ann. 40-27-101, which prohibits a party from trespassing on private lands to unlawfully collect resource data. The district court granted Defendant's motion to dismiss, concluding that the Commission had primary jurisdiction to resolve the dispute and that Plaintiff failed to exhaust its administrative remedies. The Supreme Court reversed, holding (1) Plaintiff sufficiently pleaded standing under section 40-27-101 and the Declaratory Judgments Act; (2) the district court abused in dismissing the complaint for failure to exhaust administrative remedies because the Commission did not have jurisdiction to consider Plaintiff's civil trespass claim; and (3) the court abused its discretion in relying on the primary jurisdiction doctrine. View "Devon Energy Production, LP v. Grayson Mill Operating, LLC" on Justia Law

In property dispute, the Supreme Court affirmed the judgment of the district court entering summary judgment in favor of The Nature Conservancy finding a conservation easement unambiguously burdened two parcels of property thereby limiting what the owner could construct on those parcels, holding that the district court was correct in entering summary judgment in favor of the Conservancy.Appellants, who owned the two parcels of land at issue, sought declaratory relief after the Conservancy, the administrator of the conservation easement, rejected Appellants' plan to construct buildings on each of the two parcels. The Conservancy counterclaimed for declaratory relief seeking a declaration that the conservation easement burdened and encumbered Appellants' parcels of property and limited construction on the property. The district court granted summary judgment and entered judgment on the pleadings in favor of the Conservancy. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment for the Conservancy; and (2) the district court did not err when it entered judgment on the pleadings dismissing Appellants' claims for breach of contract and breach of the covenant of good faith and fair dealing. View "Four B Properties, LLC v. Nature Conservancy" on Justia Law

In this inverse condemnation action the Supreme Court affirmed the decision of the district court entering judgment of a matter of law that Appellant failed to establish a taking and failed to provide proof of damages, holding that the trial court did not err in granting a directed verdict based on insufficient evidence of the value of Appellant's property.In her action, Appellant alleged that a road expansion project took a portion of her real property in Johnson County. The trial court entered a judgment as a matter of law, concluding that Appellant did not meet her burden to show that a taking occurred and that the evidence would be inadequate to prove any measure of damages for a partial taking. The Supreme Court affirmed, holding that the trial court properly entered a judgment as a matter of law that Appellant failed to establish a taking and failed to provide proof of damages. View "Byrnes v. Johnson County Commissioners" on Justia Law