Justia Civil Procedure Opinion Summaries

Timothy Hale and Sonja Ringen constructed a storage building on their commercially zoned property in Laramie without first obtaining a building permit. When the City of Laramie discovered the construction, it issued a stop work order and a cease-and-desist letter. Despite these notices, Hale and Ringen continued building and subsequently applied for a permit, which the City denied due to deficiencies in the application. After further unsuccessful permit attempts and ongoing disputes over the City’s requirements—including requests for disassembly of the structure—the City sought and obtained a permanent injunction from the District Court of Albany County, restricting use of the building until permitting was complete and compliance was achieved.The District Court of Albany County conducted a bench trial in May 2022 and granted the City’s request for a permanent injunction. The court outlined a process for inspections, identification of code violations, and corrective actions, but continued conflict between the parties hindered progress. Multiple rounds of correspondence, inspections, and motions ensued, with the City insisting on structural disassembly and Hale/Ringen providing documentation to support their position. Hale and Ringen eventually moved to vacate the injunction, arguing it was no longer equitable given their efforts and the City’s refusal to issue a permit. The district court denied their motion, citing only the parties’ lack of agreement, and provided no substantive analysis of the evidence.On appeal, the Supreme Court of Wyoming determined that the district court abused its discretion by failing to consider the evidence and arguments presented before denying the motion to vacate or modify the injunction. The Supreme Court held that a court must exercise discretion and decide motions on their merits, rather than requiring agreement between adversarial parties. Consequently, the Supreme Court reversed the district court’s order and remanded the case for full consideration of Hale/Ringen’s motion in light of all relevant facts and equities. View "Hale v. City of Laramie" on Justia Law

Russ and Debi Ropken hired a construction company to build a custom home based on an oral agreement. The contractor began work and sent invoices for services and materials, which the Ropkens paid until May 2022, after which they stopped making payments. In July 2022, the Ropkens removed the contractor from the site. The contractor then sent a demand letter for three unpaid invoices totaling $276,169, but the Ropkens refused to pay. The contractor sued to recover the unpaid amount.In the District Court of Park County, the Ropkens admitted owing at least $176,870.21. At the conclusion of a jury trial, the jury found there was a valid contract, the Ropkens had breached it, and awarded the contractor $258,587.70 in damages. The district court entered judgment for that amount and permitted the contractor to request prejudgment interest. The contractor timely filed for prejudgment interest, and the Ropkens objected. The district court found for the contractor, awarding $33,473.25 in prejudgment interest at a statutory rate, and calculated interest from the date of the demand letter. The Ropkens paid the judgment but appealed the prejudgment interest award.The Supreme Court of Wyoming reviewed whether the district court erred in awarding prejudgment interest and whether due process was violated by granting interest without an evidentiary hearing. The court held that a district court may award prejudgment interest even when it is not the trier of fact, as prejudgment interest is a matter of law and not fact. The court found the claim was liquidated and the Ropkens had notice. The court also held that the Ropkens received adequate notice and opportunity to be heard, satisfying due process. The Supreme Court of Wyoming affirmed the award of prejudgment interest. View "Ropken v. Yj Construction, Inc." on Justia Law

A minor child was injured in 2018 while playing on a piece of playground equipment called “Rocks and Ropes” at Meadowlark Elementary School in Cheyenne, Wyoming. The child’s parents, Scott and Heather Hunter, alleged that the equipment was defective and that the school failed in its supervision and medical care following the incident, as their daughter was diagnosed weeks later with a crushed vertebra. The Hunters sued Universal Precast Concrete, Miracle Recreation Equipment, Churchich Recreation Equipment, and Laramie County School District #1, alleging strict product liability, negligence, breach of warranty, and failure to warn.The case proceeded before the District Court of Laramie County. Due to extensive delays—including those caused by the COVID-19 pandemic—there were multiple changes to scheduling orders. The district court granted summary judgment in favor of the business defendants after excluding several of the Hunters’ expert witnesses under the Daubert standard, finding their testimony unreliable or irrelevant. The court denied summary judgment to the School District. After a mistrial was declared due to repeated improper conduct by the Hunters’ counsel during voir dire and opening statements, the district court dismissed the remaining claims against the School District with prejudice as a sanction for counsel’s actions and various procedural violations.The Supreme Court of the State of Wyoming affirmed the district court’s exclusion of the Hunters’ experts and the grant of summary judgment in favor of the business defendants, holding that the lower court properly performed its gatekeeping function and the Hunters failed to offer admissible evidence of a defect. However, the Supreme Court reversed the district court’s dismissal with prejudice, concluding that, while counsel’s conduct warranted sanctions, the extreme sanction of dismissal was not justified without prior warning or full consideration of lesser sanctions. The case was remanded for imposition of a lesser sanction. View "Hunter v. Universal Precast Concrete, Inc." on Justia Law

A property owner purchased a lot in a Wyoming subdivision governed by two homeowners’ associations, each enforcing its own set of covenants. The owner sought to demolish an existing structure and build a new residence with an attached hangar, submitting construction plans for approval as required. Disputes arose over whether his application was complete and whether the associations unreasonably delayed or withheld approval, resulting in increased construction costs due to inflation. Complicating matters, one association (AVR I) had been dissolved years earlier, but its board continued to act as if it existed, later forming a new entity (AVR II) that purported to enforce covenants recorded after AVR I’s dissolution but before AVR II’s formal creation.The property owner initially sued AVR I, believing it to be the proper party, and later sued the other association, AAA. During discovery, he learned that AVR I had been defunct and that AVR II was the actual entity acting as the homeowners’ association. He moved to amend his complaint to add AVR II and assert new claims, including that the covenants were invalid. The District Court of Lincoln County denied the motion to amend, finding the amendments would be futile, and granted summary judgment to AVR I, reasoning that the covenants automatically approved the owner’s plans by default and any delay was self-imposed.The Supreme Court of Wyoming reviewed the case and held that the district court abused its discretion in denying leave to amend the complaint. The Supreme Court found that the proposed claims against AVR II were not futile, as there were unresolved factual and legal questions regarding the validity and enforceability of the covenants and AVR II’s authority. The court also held that summary judgment for AVR I was premature. The orders denying amendment and granting summary judgment were reversed, and the case was remanded for further proceedings. View "Conger v. AVR Homeowner's Association, Inc." on Justia Law

Burke McCarthy died in October 2018 after receiving medical treatment from Dr. Wesley Hiser at Wyoming Medical Center. Dianna Ellis, McCarthy’s daughter and wrongful death representative, filed a wrongful death lawsuit against Dr. Hiser and the hospital in February 2021, within the two-year statute of limitations. However, Dr. Hiser was never served with the original complaint. Nearly two years later, Ellis voluntarily dismissed her suit against Dr. Hiser. In December 2023, she refiled her complaint, relying on Wyoming’s savings statute to argue she had an additional year to commence a new action. Dr. Hiser was served for the first time in February 2024, more than five years after McCarthy’s death.The District Court of Natrona County granted Dr. Hiser’s motion to dismiss the refiled complaint. The court found that it had never obtained jurisdiction over Dr. Hiser in the original action because he was not served, and therefore the savings statute could not apply to extend the time for refiling. Ellis appealed this decision.The Supreme Court of Wyoming reviewed the case de novo. The court held that Wyoming’s savings statute, Wyo. Stat. Ann. § 1-3-118, does not apply to actions that are voluntarily dismissed by the plaintiff. The court overruled its prior decision in Hugus v. Reeder, 2022 WY 13, which had held that a voluntary dismissal qualified as a “failure otherwise than upon the merits” under the savings statute. The court reasoned that a voluntary dismissal is not a “failure” within the meaning of the statute, as it is a matter of choice rather than an unsuccessful attempt to proceed. Accordingly, the Supreme Court of Wyoming affirmed the district court’s dismissal of Ellis’s refiled complaint. View "Ellis v. Hiser" on Justia Law

Robert Redland's parents accumulated ranching property in the Big Horn Basin, which Robert and his wife, Irene, later purchased. They raised their five children on these properties and created the Robert and Irene Redland Family Trust in 1989 to manage the ranch properties. Robert promised his children that all ranch properties would be placed in the trust, except for the Manderson Place, which would be placed in the trust after his and Irene's deaths. In 2007, Robert and Irene sold an 11-acre parcel of the Manderson Place to their daughter Lisa and her husband, Mike Kimsey. The Redland Children discovered that the Manderson Place and other properties were not in the trust and sued Robert and the Kimseys.The District Court of Big Horn County initially ruled that Robert must transfer the disputed properties to the trust, including the 11 acres sold to the Kimseys. However, the court later amended its judgment, removing the requirement for the 11 acres to be transferred to the trust, as the Redland Children had not stated a claim against the Kimseys for the return of the 11 acres. The Redland Children did not appeal this amendment.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision, except for the provision regarding the Manderson Place, which it ordered to be transferred to the trust immediately, subject to a life estate in Robert. The district court then issued a judgment excluding the 11 acres from the trust, which the Redland Children appealed.The Wyoming Supreme Court held that its previous decision did not require the 11 acres to be transferred to the trust and that the district court did not abuse its discretion in denying the Redland Children's motions to amend their complaint and for attorney fees. The court affirmed the district court's judgment exempting the 11 acres from being transferred to the trust. View "Redland v. Kimsey" on Justia Law

Thomas Hamann brought a lawsuit against Heart Mountain Irrigation District (HMID) and its manager, Randy Watts, alleging that HMID, through Watts' actions, damaged his property and caused him bodily injury. Hamann sought damages based on claims of inverse condemnation and violation of his constitutional rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of HMID and Watts, dismissing Hamann’s lawsuit entirely. Hamann appealed only the dismissal of his inverse condemnation claim against HMID.The district court found that HMID had not taken any official action to authorize Watts to enter Hamann’s property beyond the limited scope of work on the Riolo bowl, which Hamann had consented to. The court held that without such authorization, Hamann’s inverse condemnation claim could not survive summary judgment. Hamann argued that there was a material issue of fact regarding whether Watts was acting under the scope, authority, and direction of HMID’s board.The Wyoming Supreme Court reviewed the case and found that there were genuine issues of material fact regarding the extent of Watts’ authority and whether his actions were authorized by HMID. The court noted that HMID’s bylaws allowed for delegation of responsibilities to its manager and other agents, and there was evidence suggesting that Watts had general discretion as HMID’s manager. Additionally, there was conflicting testimony about whether Watts had specific authorization to access Hamann’s property beyond the Riolo bowl.The court concluded that the district court erred in granting summary judgment to HMID, as there were unresolved factual issues regarding the authorization of Watts’ actions and the extent of damage to Hamann’s property due to activities on adjoining land. The Wyoming Supreme Court reversed the district court’s order and remanded the case for further proceedings. View "Hamann v. Heart Mountain Irrigation District" on Justia Law

A mother appealed the dismissal of a neglect case brought against her by the State of Wyoming. The case involved her two children, AB and JC. The mother was arrested for drug-related charges, and the children were placed in protective custody. JC was released to his father, who had primary custody, while AB was released to his paternal grandfather and later to his father, who lived in Texas. The State filed a neglect petition, and the juvenile court held hearings, during which the mother denied the allegations. The court initially placed AB with his paternal grandfather and later with his father.The juvenile court found the children had been neglected and ordered continued placement with their fathers while the mother completed a case plan. The State moved to dismiss the neglect petition after the mother made progress on her case plan and AB's father sought custody. The juvenile court initially dismissed the petition but vacated the dismissal after the mother objected. The court later set a permanency review hearing and maintained the status quo, allowing the mother to continue working on her case plan.The State again moved to dismiss the case, noting the mother’s progress and the existence of custody agreements for both children. The juvenile court dismissed the neglect petition, and the mother appealed. The Wyoming Supreme Court found the appeal moot because the State had dismissed the neglect action, and the mother had physical custody of AB. The court concluded that any judgment would have no practical effect on the existing controversy and dismissed the appeal. The court also determined that none of the exceptions to the mootness doctrine applied in this case. View "In the Interest Of: AB and JC" on Justia Law

Jackson Hole Hereford Ranch, LLC (JHHR) sought to partition real property it claimed to own as a tenant in common with Leeks Canyon Ranch, LLC (Leeks). Leeks counterclaimed, asserting sole ownership based on judicial estoppel, equitable estoppel, and adverse possession. The district court granted partial summary judgment to JHHR, dismissing Leeks’s judicial and equitable estoppel claims. After a bench trial, the court ruled against Leeks on the adverse possession claim. Leeks appealed both the summary judgment and the trial findings.The District Court of Teton County granted summary judgment to JHHR on Leeks’s judicial and equitable estoppel claims. The court found that Mr. Gill, representing JHHR, had forgotten about his 25% interest in the property during arbitration, negating the application of judicial estoppel. The court also found no evidence of willful misconduct or serious negligence by Mr. Gill, which is necessary for equitable estoppel. The court held that Mr. Gill’s statements during arbitration were not sufficient to establish estoppel.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The Supreme Court agreed that judicial estoppel did not apply because Mr. Gill’s prior position was based on a mistake. The court also upheld the summary judgment on equitable estoppel, finding no evidence of willful misconduct or serious negligence by Mr. Gill. Regarding adverse possession, the Supreme Court found that Leeks failed to prove that its possession of the property was hostile to JHHR’s interest. The court noted that Leeks did not provide clear notice to JHHR that its ownership was in jeopardy, a requirement for adverse possession among cotenants. The Supreme Court affirmed the district court’s rulings in favor of JHHR. View "Leeks Canyon Ranch, LLC v. Jackson Hole Hereford Ranch, LLC" on Justia Law

Rick Holloway and John Hoskin entered into a Commercial Sales Agreement to purchase the UXU Resort Ranch from Hidden Creek Outfitters, LLC. The sale included a special use permit from the U.S.D.A. Forest Service, which required a bridge inspection and load test before transfer. Due to the inspection's delay, the parties postponed closing and placed $200,000 in escrow for bridge-related expenses. After inspections, Park County Title released the escrow funds to Hidden Creek without H&H's consent, despite unresolved bridge issues.The District Court of Park County found that Hidden Creek and H&H each breached the implied covenant of good faith and fair dealing, and Park County Title breached the escrow agreement by releasing funds without H&H's approval. However, the court determined H&H failed to prove actual damages with sufficient certainty, awarding only nominal damages. The court also denied attorney’s fees to all parties.The Supreme Court of Wyoming reviewed the case and affirmed the district court's findings. The court held that H&H did not prove actual damages because the inspections did not conclusively identify necessary or required repairs. The court also upheld the denial of attorney’s fees, finding no abuse of discretion, as both parties bore some fault in the litigation. The Supreme Court denied any attorney’s fees associated with the appeal. View "Holloway v. Hidden Creek Outfitters, LLC" on Justia Law