Jean Best v. Brianna Best
2015 WY 133
| Wyo. | 2015Background
- Brianna Best sued Jean Best and VALIC in circuit court under Wyoming's Declaratory Judgments Act, seeking a declaration she was entitled to proceeds from her deceased father's retirement annuity accounts and payment of the account funds (monetary relief).
- Brianna alleged the amount in controversy did not exceed $50,000 and invoked circuit court jurisdiction under Wyo. Stat. § 5-9-128(a)(i).
- The circuit court granted summary judgment for Jean, declaring Jean the designated beneficiary and ordering VALIC to distribute the proceeds.
- On appeal the district court reversed jurisdictionally, holding that declaratory judgment actions fall exclusively within district court jurisdiction regardless of the amount in controversy.
- The Wyoming Supreme Court granted review to decide whether a circuit court may hear a declaratory judgment action when it has an independent basis for jurisdiction (here, the $50,000 statutory limit).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a circuit court may hear a declaratory judgment action when the relief sought is within its $50,000 monetary jurisdiction | Brianna: Declaratory relief sought includes payment of account funds ≤ $50,000, so circuit court has jurisdiction under § 5-9-128(a)(i) | Jean/District Ct: Declaratory Judgment Act actions must be in district court; circuit courts lack jurisdiction over declaratory actions regardless of amount | Held: Circuit court may hear declaratory actions if it has an independent basis for jurisdiction (e.g., the statutory $50,000 limit); Declaratory Judgments Act does not itself confer jurisdiction. |
Key Cases Cited
- Harmon v. Star Valley Med. Ctr., 331 P.3d 1174 (Wyo. 2014) (standard: subject-matter jurisdiction reviewed de novo)
- William F. West Ranch, LLC v. Tyrrell, 206 P.3d 722 (Wyo. 2009) (Declaratory Judgments Act does not extend court jurisdiction)
- Lieberman v. Wyoming.com LLC, 11 P.3d 353 (Wyo. 2000) (monetary relief awarded in declaratory judgment action)
- Farr v. Link, 746 P.2d 431 (Wyo. 1987) (declaratory judgment can include monetary relief based on disputed contractual rights)
- State Farm Mut. Auto. Ins. Co. v. Kunz, 186 P.3d 378 (Wyo. 2008) (a judgment rendered without subject-matter jurisdiction is void)