Byrnes v. Harper, 411 P.3d 427

Byrnes sold Johnson County property to Michael and Carla Harper by contract for deed (Sept 1, 2015); Byrnes retained the deed pending final payment.
In Nov 2015 Harpers obtained financing and sought to prepay and obtain delivery of the deed; Byrnes refused to deliver.
Harpers filed a declaratory judgment action (Sept 1, 2016) asking the contract allowed early payoff and required delivery of the deed; Byrnes answered Sept 20, 2016.
Court granted Harpers’ motion to compel discovery; bench trial held March 10, 2017, and court announced ruling for Harpers; written declaratory judgment entered April 10, 2017.
Court later awarded Harpers attorneys’ fees and costs for Byrnes’ discovery violations (May 3, 2017); Byrnes filed a post-judgment ‘‘motion for reconsideration’’ (Apr 20) and then filed a notice of appeal (May 22).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of appeal from April 10 declaratory judgment	Byrnes treated her motion for reconsideration as tolling the appeal period	Harpers argued the motion was just a request for reconsideration and did not toll the appeal deadline	Motion was substantively a reconsideration request (not a Rule 59 motion); appeal dismissed as untimely
Challenge to order awarding fees and costs for discovery violations	Byrnes argued the award was improper (no cogent briefing or record citations)	Harpers defended the award and cited discovery violations	Affirmed summarily for lack of cogent argument and failure to cite the record or authority
Effect/appealability of motion for reconsideration	Byrnes relied on her motion to vacate/reconsider to preserve appeal rights	Harpers argued such motions are nullities for tolling purposes and denial is not appealable	Motion did not toll appeal; denial is not appealable; motion treated as nullity
Sanctions under W.R.A.P. 10.05	Byrnes did not present record citations or legal authority to justify appeal	Harpers requested sanctions for unreasonable appeal and poor briefing	Court certified no reasonable cause and permitted Harpers to submit fee statement for sanctions under W.R.A.P. 10.05

Lokey v. Irwin, 374 P.3d 311 (Wyo. 2016) (substance of post-judgment filing controls whether appeal period is tolled)
Waldron v. Waldron, 349 P.3d 974 (Wyo. 2015) (post-judgment motion that merely requests reconsideration does not toll appeal time)
DW v. State, 395 P.3d 184 (Wyo. 2017) (affirmance rule for appeals lacking cogent argument or authority)
Burnett v. Burnett, 394 P.3d 480 (Wyo. 2017) (pro se litigants receive some leniency but must adhere to procedural rules; sanctions available)
Hodgins v. State, 1 P.3d 1259 (Wyo. 2000) (pro se litigants must reasonably comply with procedural requirements; sanctions for noncompliance)
Hamburg v. Heilbrun, 891 P.2d 85 (Wyo. 1995) (courts may summarily affirm where appellant fails to present cogent argument)
Basolo v. Gose, 994 P.2d 968 (Wyo. 2000) (sanctions appropriate where appeal lacks cogent argument or record citation)
Plymale v. Donnelly, 125 P.3d 1022 (Wyo. 2006) (motions for reconsideration are treated as nullities for tolling/appealability purposes)