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Real Estate

Wyoming Supreme Court
Uncategorized

Cross v. Albright — Mediated Settlement Email Unenforceable Where Parties Never Agreed on Mechanism for Ditch Access or Storage Restriction

The Wyoming Supreme Court affirmed a finding that a mediated settlement email was unenforceable because the parties never agreed on whether ditch access would be implemented through an easement, license, or other interest and never specified whether a storage restriction would run with the land or remain a personal obligation, leaving essential terms undefined and creating at most an agreement to agree.

Wyoming Supreme Court
Uncategorized

Lewis v. Wolfe — Quiet Title Decree Naming “Husband and Wife” Creates Tenancy by Entirety Under Longstanding Wyoming Common Law

The Wyoming Supreme Court affirmed dismissal of a daughter’s declaratory judgment action seeking to establish that her late father’s interest in real property passed to his estate rather than to her mother by survivorship. The court held that a 2012 quiet title decree identifying the parents as “Husband and Wife” created a tenancy by the entirety under longstanding Wyoming common law, and that the 2023 codification of that presumption in Wyoming Statute § 34-1-140(b) merely clarified — rather than changed — pre-existing law.

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