Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court vesting title to a portion of Louise Galiher’s property in Dennis and Vicky Johnson by adverse possession, holding the district court’s findings of fact were not clearly erroneous and that the facts supported a finding of adverse possession.Galiher sued to quiet title to the disputed property, alleging that the Johnsons’ use of her property had been permissive. The Johnsons counterclaimed, seeking to quiet title to the disputed parcel based upon adverse possession. The district court concluded that the Johnsons had proven their adverse possession claim. The Supreme Court reversed and remanded for consideration of the totality of the evidence. On remand, the district court again concluded that title to the parcel had vested in the Johnsons. The supreme Court affirmed, holding that the district court’s conclusion was supported by the record. View "Galiher v. Johnson" on Justia Law

The Supreme Court affirmed an order denying Appellant’s claim that his paintings were statutorily exempt from execution to satisfy a judgment debt, holding that the district court did not err in concluding that the paintings were not exempt from execution as “pictures” under Wyo. Stat. Ann. 1-20-106(a)(i).RADC/CADC Venture, LLC, which obtained a judgment against Appellant for nearly two million dollars, assigned its interest in the judgment to Radiance Capital Receivables Nineteen, LLC (Radiance). Radiance then applied for a writ of execution to be issued against Appellant’s real, personal and equitable assets located in Teton County. The Teton County Sheriff attached Appellant’s property, which included more than thirty works of art consisting primarily of paintings. On appeal, Appellant argued that his paintings were “pictures” that qualified for the exemption set forth in section 1-20-106(a)(i). The Supreme Court affirmed, holding that the term “pictures” in the statute did not extend to Appellant’s paintings. View "Crow v. 2010-1 RADC/CADC Venture, LLC" on Justia Law

The Supreme Court affirmed the order of the district court affirming the decision of the Wyoming State Board of Equalization (state) reversing the decision of the Washakie County Board of Equalization (county board) reversing the valuations of the Washakie County Assessor classifying Taxpayers’ four properties as either residential or vacant residential for tax purposes, holding that Taxpayers’ property did not qualify for classification as agricultural lands.Taxpayers separately owned four parcels of land in Washakie County, Wyoming. In March 2014, the Assessor issued notices of assessment for Taxpayers’ properties classifying the parcels as either residential or residential vacant. The county board reversed the valuations, concluding that Taxpayers had demonstrated that their properties met the four requirements under Wyo. Stat. Ann. 39-13-103(b)(x)(B) to be taxed as agricultural land. The state board reversed. The district court affirmed. The Supreme Court affirmed, holding that Taxpayers failed to meet their burden to overcome the presumption in favor of the Assessor’s assessments. View "Helmut v. Mueller Limited Partnership v. Treanor" on Justia Law

The Supreme Court affirmed the district court’s decision ruling generally in favor of Judy Weeks-Rohner in this quiet title action brought by the Estate of Jack Winford Weeks, holding that there was no error or abuse of discretion.When Jack Weeks and Judy Weeks-Rohner divorced, the divorce decree directed that their jointly owned home would remain in Weeks’ possession, subject to a trust for their minor son. The trust, however, was never formed. After the son and then Weeks died, the Estate of Jack Weeks filed a quiet title action against Weeks-Rohner, asserting adverse possession of the property. Weeks-Rohner counterclaimed, requesting that the court enforce the divorce decree by quieting title to the property in the deceased son and/or his heirs. The district court ruled generally in favor of Weeks-Rohner. The Supreme Court affirmed, holding (1) the district court did not err in quieting title to the property in both parties with each owning an undivided one-half interest as tenants in common; (2) there was no error in the district court’s rejection of the Estate’s adverse possession claim; and (3) the court was within its inherent authority when it enforced its decree by ordering the parties to place the property in a trust for the deceased son. View "Estate of Jack Winford Weeks v. Weeks-Rohner" on Justia Law

The Supreme Court affirmed the jury verdict awarding Basic Properties, Inc. $200,000 in damages for Essex Holding, LLC’s refusal to consent to amend restrictive covenants to allow Basic to develop one of its lots in a shopping center. The Court held (1) Essex timely filed its notice of appeal; (2) Basic had standing to assert its counterclaim; (3) the district court did not err when its submitted Basic’a counterclaim for breach of contract to the jury; (4) the jury instructions rejecting Essex’s theory regarding a void amendment did not constitute plain error; (5) cumulative error did not result in an excess verdict or a verdict contrary to law; (6) the district court properly granted basic’s motion for judgment as a matter of law on Essex’s anticipatory repudiation claim; (7) the district court did not err in its award of attorney fees and costs to Basic; and (8) the district court properly denied Essex’s Wyo. R. Civ. P. 60(b) motion. View "Essex Holding, LLC v. Basic Properties, Inc." on Justia Law

The Supreme Court affirmed the district court’s dismissal of Plaintiff’s declaratory judgment action against the Laramie County Clerk asking that a Notice of Federal Tax Lien (NFTL) be declared invalid and the NFTL be removed from Plaintiff’s property record, holding that the complaint failed to state a cognizable claim.In 2007, the IRS filed the NFTL at issue against real property owned by Plaintiff. In 2017, Plaintiff filed this action. The district court dismissed the complaint, determining that it was barred by the applicable statute of limitations and that it failed to state a claim for which relief may be granted under Wyo. R. Civ. P. 12(b)(6). The Supreme Court affirmed after finding a single issue as dispositive, holding that the district court did not err in dismissing the complaint for failure to state a claim because a county clerk has no authority or discretion to consider the underlying basis for a federal tax lien or notice of lien, or to declare the invalidity of the lien, which is the relief Plaintiff sought. View "Tuttle v. Lee" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment to Defendants in this quiet title action challenging the enforceability of a plat restriction that barred Plaintiffs’ use of a portion of their own property.Plaintiffs owned Lot 8 in a subdivision. Defendants owned Lot 7. The plat restriction at issue in this case barred Plaintiffs’ use of a portion of Lot 8 and gave exclusive use of and responsibility for that property to Defendants. The district court concluded that the plat restriction contained in the subdivision’s recorded plat created an enforceable covenant appurtenant to Lot 8. The Supreme Court affirmed, holding (1) the plat restriction did not fail for lack of definition; (2) Plaintiffs’ challenges to the enforceability of the plat restriction on public policy grounds failed; and (3) there was no impediment in an access easement to the enforceability of the plat restriction. View "Reichert v. Daugherty" on Justia Law

The Supreme Court affirmed the decision of the district court quieting title on the mineral rights in lands conveyed by two deeds in 1913 in Box Creek Mineral Limited Partnership.Box Creek brought this action against BNSF Railway Company seeking to quiet title in the mineral rights at issue. The parties disputed whether the 1913 deeds passed a fee simple estate from Box Creek to BNSF, thereby conveying the underlying mineral estate, or if the deeds merely conveyed an easement in fee simple, whereby the minerals would not pass to BNSF. The district court concluded that the deeds were ambiguous and that the parties intended an easement-like conveyance rather than a fee simple interest and quieted title to the mineral estate in Box Creek. The Supreme Court affirmed, holding (1) the district court correctly concluded that the parties intended a limited grant from Box Creek to BNSF, in what amounted to an “easement-like conveyance"; and (2) the district court properly admitted the testimony of Marc Strahn as expert witness testimony. View "BNSF Railway Co. v. Box Creek Mineral Limited Partnership" on Justia Law

The Supreme Court affirmed the district court’s order granting Heather Hope Schumacher’s motion to enforce a settlement agreement she entered into with Cowboy’s LLC after Cowboy’s failed to pay Schumacher the money as agreed.Schumacher claimed that her divorce decree awarded her certain property, that her ex-husband failed to convey the property to her, and that she had filed lien statements against the disputed property, which was then owned by Cowboy’s. The parties eventually reached a settlement agreement requiring Cowboy’s to pay Schumacher $98,742 in return for her release of all liens against the property. When Cowboy’s failed to pay Schumacher as agreed, Schumacher sought an order requiring Cowboy’s to comply with the settlement agreement. The district court ordered Cowboy’s to perform as agreed. The Supreme Court affirmed, holding (1) Schumacher’s liens were valid and enforceable; and (2) the “deemed denial” of Cowboy’s motion to set aside the order enforcing the settlement agreement was properly denied. View "Cowboy's LLC v. Schumacher" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment in favor of Bank in this quiet title action.Plaintiff filed suit seeking to quiet title to property he purchased at a tax sale. Bank, the mortgagee on the property and a defendant in the quiet title suit, alleged that Plaintiff’s tax deed was void. The district court granted summary judgment for Bank, concluding that the statutorily-required notice regarding redemption provided by Plaintiff to the property owner and to Bank was deficient and that the tax deed was void. The Supreme Court affirmed, holding (1) Bank had standing to challenge the validity of Plaintiff’s tax deed; (2) because Plaintiff failed to notify Bank of the redemption period, the tax deed was void; (3) the district court’s reference to a document not contained in the record was error, but it was not reversible error because that document was not relevant to the material facts in this case; (4) the doctrine of laches and unclean hands did not bar Bank’s arguments regarding the validity of the tax deed; and (5) Plaintiff’s statutory claims for reimbursement were not ripe for review. View "Montierth v. Deutsche Bank National Trust Co." on Justia Law