Justia Wyoming Supreme Court Opinion Summaries

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

The Supreme Court dismissed this appeal from the decision of the district court reversing the decision of the director of the Wyoming Department of Environmental Quality (WDEQ) and the Environmental Quality Council (EQC) denying Brook Mining Company's application for a permit to develop and operate a new surface coal mine, holding that the issues presented in this appeal were moot.The EQC concluded that the permit application was deficient and denied Brook Mining Company's application. The Director of the WDEQ then denied the permit. The district court reversed. While this appeal was pending, Brook Mining Company submitted a revised permit application. The Director issued a decision that approved the revised permit application. Also while the appeal was pending, the legislature changed the regulatory structure for the approval of new coal mine applications by removing the opportunity for an EQC contested case hearing prior to the Director's decision. The Supreme Court dismissed the appeal, holding that the issues in this appeal do not continue to present a justiciable controversy and have thus become moot. View "Fisher v. Wyoming Department of Environmental Quality" on Justia Law

The Supreme Court reversed in part the district court's final judgment incorporating the jury's special verdict in favor of the Goddards and rendering judgment in favor of Sand Creek Ranch Preservation Association, Inc. (SCRPA) and against Goddard Ranch on two of its claims for declaratory relief that were not included in the jury's verdict, holding that SCRPA and Johnson County Ranch Improvement #1 (JCRI) waived their arguments on appeal and that the district court erred in entering final judgment on SCRPA's claims for declaratory relief.Goddard Ranch, LLC purchased ranch lands in a subdivision where private home lots were surrounded by ranch land. The fence encroached upon easements belonging to the homeowners. JCRI and SCRPA, whose members were owners of the residential lots, sued Goddard Ranch and three individuals (collectively, the Goddards). The jury returned a special verdict for the Goddards. The final judgment incorporated the special verdict and rendered judgment in favor of SCRPA on two of its claims for declaratory relief that were not included in the jury's verdict. The Supreme Court held (1) the arguments SCRPA and JCRI on appeal were not reviewable; and (2) there was no justiciable controversy with respect to SCRPA's claims for declaratory relief concerning SCRPA's right to install signage and certain facilities within the easements. View "Johnson County Ranch Improvement #1, LLC v. Goddard" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment and issuing a declaratory judgment and judgment quieting title to real property in favor of Defendants after concluding that Plaintiffs' predecessors in title conveyed a 1/8 mineral interest to Roy Barton in 1989, holding that a 1989 deed conveyed an unrestricted 1/8 mineral interest.Plaintiffs brought this suit, asserting ownership of a royalty interest in the property at issue. The district court granted summary judgment in favor of B&G followed by a declaratory judgment and judgment quieting title to Defendants to a 1/8 mineral interest, including all royalty interests in the 1/8 mineral interest. The Supreme Court affirmed, holding (1) the 1989 deed conveyed an unrestricted mineral interest without reserving a separate royalty interest; and (2) Defendants were not entitled to attorneys' fees and costs. View "Smith v. B&G Royalties" on Justia Law

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