Management Nominees, Inc., a Belize corporation and Alderney Investments, LLC, a Wyoming Limited Liability Company v. Edyta Skowronska, individually and on behalf of her minor children, RS and DS, 450 P.3d 672

Alderney Investments LLC was formed in Wyoming in 1999; two Panamanian nominee companies (MNI-Panama and Nominees-Panama) were listed as its members while a chain of trusts (M&M and UEB) concealed the true beneficiaries.
Rudolf Skowronski designed the nominee-trust structure; his sister Dagmara exercised control via a power of attorney and a “chain of control” directing trustees to act for beneficiaries.
Dagmara allegedly transferred her interest to her husband Rico Sieber in 2003 (no signed transfer documents); Rico and representatives later caused the Panamanian members to assign their membership interests to MNI-Belize in 2012.
Edyta (Rudolf’s wife) claims that in 2005 Dagmara transferred 90% beneficial interest to Edyta and two children (Exhibits J & K); Dagmara denied those documents’ authenticity; a forensic examiner testified they were genuine.
After Edyta filed Articles of Dissolution in 2013, MNI-Belize sued; a jury found MNI-Belize not sole member, the dissolution was unauthorized, and Edyta and her children were 90% beneficial owners. The district court denied MNI-Belize’s renewed Rule 50 JML motions.
The Wyoming Supreme Court affirmed, holding that the contested facts presented reasonable competing inferences for the jury to resolve.

Issue	Plaintiff's Argument (MNI-Belize)	Defendant's Argument (Edyta)	Held
1) Sufficiency of evidence that Edyta and two children are 90% beneficial owners	Jury verdict unsupported; Exhibits J & K were outliers against long paper trail showing Dagmara transferred control to Rico	Presented documents (J & K) and forensic signature evidence; Rico’s testimony undermined his ownership claim	Affirmed — sufficient evidence for jury to find Edyta and children 90% beneficial owners
2) JML that MNI-Belize is sole member of Alderney	Assignment to MNI-Belize was valid and completed; no invalidating defects	Trustees could not validly transfer membership without direction from the beneficial owner; conflicting proof created a factual question	Denied — factual disputes made membership a jury question
3) JML that Edyta is disqualified from management because she wrongfully dissolved Alderney	A wrongful dissolution disqualifies her from management under §17-29-407(e) as a matter of law	Section disqualifies members/managers, not beneficial owners; MNI-Belize failed to raise the argument timely	Denied — statute’s disqualification applies to members/managers and issue was not properly preserved for Rule 50(b) relief

Merit Energy Co., LLC v. Horr, 366 P.3d 489 (Wyo. 2016) (Rule 50 JML reviewed de novo; grant cautiously)
Essex Holding, LLC v. Basic Properties, Inc., 427 P.3d 708 (Wyo. 2018) (court must enter JML where evidence legally insufficient)
Bellemare v. Clermont, 870 N.E.2d 624 (Mass. App. Ct. 2007) (describing nominee trusts and beneficiaries’ control)
In re Grand Jury Subpoena, 973 F.2d 45 (1st Cir. 1992) (nominee trustee acts only at beneficiary direction)
Brown v. Grady, 92 P. 622 (Wyo. 1907) (special agent cannot bind principal by unauthorized conveyance)
Wyo. Med. Ctr., Inc. v. Murray, 27 P.3d 266 (Wyo. 2001) (jury resolves factual conflicts; appellate review gives effect to verdict)
Landsiedel v. Buffalo Properties, LLC, 112 P.3d 610 (Wyo. 2005) (sufficiency review assumes evidence favorable to prevailing party is true)