Byrnes v. Harper, 435 P.3d 364

J. Michaela Byrnes sold property to Michael and Carla Jo Harper under a contract for deed; Harpers sued for declaratory judgment to prepay the contract and obtain a deed.
In a prior appeal (Byrnes I), this Court dismissed Byrnes' appeal as untimely, affirmed fees/costs, and granted sanctions against Byrnes.
After that affirmance, the district court held a hearing and issued an Order After Hearing setting the stipulated payoff amount for the contract for deed.
Byrnes, proceeding pro se, appealed the Order After Hearing but largely re-litigated issues resolved in Byrnes I and submitted an untimely, substantive "Notice of Errata" that the Court treated as improper.
The Court found Byrnes’ brief noncompliant with appellate rules, largely unintelligible, and failing to present argument or cite authority relevant to the payoff-order on appeal.

Issue	Byrnes' Argument	Harpers' Argument	Held
Whether Harpers may prepay contract for deed / obtain deed	Harpers cannot prepay; (re-argues issues from Byrnes I)	Harpers entitled to prepay as previously adjudicated	Court affirms district court; Harpers may prepay and payoff amount stands
Whether appeal is procedurally proper / brief complies with W.R.A.P.	Byrnes asserts corrections via Notice of Errata and advances new authority	Harpers argue appeal lacks cogent argument and is untimely/inappropriate	Court finds Byrnes’ filings noncompliant, disregards errata, and summarily affirms
Whether appellate sanctions/fees are warranted	Byrnes offers no substantive response on sanctions	Harpers request fees/costs under W.R.A.P. 10.05	Court certifies no reasonable cause for appeal and allows Harpers to submit statement of fees/costs for award
Scope of review: whether appellate court should revisit issues decided in Byrnes I	Byrnes attempts to reargue declaratory-judgment holdings	Harpers rely on finality of prior ruling and limited scope to payoff-order	Court refuses to revisit Byrnes I issues and confines review to payoff-order

Byrnes v. Harper, 411 P.3d 427 (Wyo. 2018) (prior appeal where this Court dismissed Byrnes' untimely appeal and affirmed fees and sanctions)
Hodgins v. State, 1 P.3d 1259 (Wyo. 2000) (pro se litigants get some leniency but must comply with procedural rules; sanctions appropriate for noncompliance)
Young v. State, 46 P.3d 295 (Wyo. 2002) (affirming that pro se parties must reasonably adhere to rules and sanction authority exists)
Burnett v. Burnett, 394 P.3d 480 (Wyo. 2017) (supports awarding sanctions where appeals lack cogent argument or adequate record citation)