Cindy A. Sharpe George A. Logan and Sybille Ranch, Llc v. Judith Timchula, Trustee of the Judith Timchula Living Trust Dated October 19, 2000, and Jack Garson Aletha Garson Jimmy Ray Garson Molly Jane Garson Shan Brian Garson and Strong Creek Ranch, Inc., 453 P.3d 761

Judith Timchula (trustee) owned a landlocked section and sued under Wyo. Stat. §§ 24-9-101 to -105 to establish a private road to public Highway 34.
The court appointed three viewers to inspect proposed routes; viewers recommended a modified route (the Viewers’ Route) avoiding state land and providing closer, more dependable access.
Opposing landowners (Sharpe, Logan, Sybille Ranch, and the Garsons) proposed an alternate Section 22 route that largely follows existing road and easements; they also sought use restrictions (e.g., limiting use to agricultural/residential and prohibiting subdivision).
The district court adopted the Viewers’ Route, refused to impose the requested use restrictions, and accepted the viewers’ damages recommendation ($25 per rod to some owners; $500 to the Garsons).
On appeal the Wyoming Supreme Court affirmed the route selection and rejection of use restrictions, but reversed the damages award because the viewers did not perform the statutory “before and after” appraisals and remanded for recalculation of damages in accordance with § 24-9-101(j).

Issue	Plaintiff's Argument (Timchula)	Defendant's Argument (Sharpe/Logan/Sybille/Garsons)	Held
1. Whether the court selected the "most reasonable and convenient" route	Viewers’ Route reasonable; court should follow viewers	Section 22 route is shorter, follows existing road, avoids homesites/wet areas	Affirmed: Court did not clearly err; Viewers’ Route closer to highway and more dependable per viewers/court
2. Whether court should impose use restrictions on the private road	Opposed restrictions; property rights should not be limited without basis	Proposed restrictions to prevent subdivision and limit use to agricultural/residential	Affirmed: Court permissibly declined restrictions—insufficient evidence and other easements lacked such limits
3. Whether damages award was proper	Damages based on $25/rod/state baseline or comparable easement prices acceptable	Opposed the viewers’ methodology; sought lawful appraisal under statute	Reversed on damages: Statute requires before-and-after appraisals; remand for proper valuation

Lindt v. Murray, 895 P.2d 459 (Wyo. 1995) (establishing before-and-after measure for private road damages)
Mayland v. Flitner, 28 P.3d 838 (Wyo. 2001) (applies before-and-after approach under private road statute)
Barlow Ranch, Ltd. P’ship v. Greencore Pipeline Co. LLC, 301 P.3d 75 (Wyo. 2013) (distinguishes private-road damages from eminent-domain appraisal methods)
Closs v. Schell, 139 P.3d 435 (Wyo. 2006) (holding that an entirely new road not connecting to existing easements may be unreasonable)
Whaley v. Flitner Ltd. P’ship, 395 P.3d 653 (Wyo. 2017) (declining to overturn route selection where choice between routes was close)
In re Crago, 168 P.3d 845 (Wyo. 2007) (similar deference to factfinder on competing routes)
Miner v. Jesse & Grace, LLC, 317 P.3d 1124 (Wyo. 2014) (appellate standard: bench findings reviewed for clear error)