Moose Hollow Holdings, Llc, F/K/A Moose Hollow, Llc and Blue Skies West, Llc v. Teton County Board of County Commissioners and Jcft Wyoming Real Estate, Llc, 396 P.3d 1027

Moose Hollow and Blue Skies own adjacent residential parcels in rural Teton County; JCFT owns two parcels (53.2 acres and 6 acres) that were formerly a single 59.2-acre tract subject to a 2006 development permit (DEV2004-0024) and a conservation easement.
Appellants requested a formal rule interpretation whether DEV2004-0024 had expired; JCFT requested a zoning compliance verification (ZCV) confirming the six-acre parcel’s legal status and potential development rights.
On April 17, 2015 the planning director: (1) concluded DEV2004-0024 was vested and may be amended; and (2) opined the six-acre parcel was legally recognizable and that it could be eligible for up to 10,000 sq ft of floor area if certain amendments and permits were approved.
Appellants appealed both determinations to the Teton County Board of County Commissioners; JCFT intervened. The Board dismissed the appeals for lack of standing and (as to the ZCV) untimeliness.
The district court affirmed the Board. The Wyoming Supreme Court affirmed, holding Appellants lacked standing and that the planning director’s rulings were not ripe for judicial review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to appeal planning director’s rule interpretation	Appellants argued they are aggrieved property owners who will suffer aesthetic, safety, and pecuniary harms from further development	County/JCFT argued the director’s determinations did not approve development and alleged harms were speculative	No standing: alleged harms are contingent on future permit approvals and thus speculative
Ripeness of challenge to rule interpretation and ZCV	Appellants urged immediate review to prevent harm from foreseeable development	County/JCFT argued decisions were preliminary, nonbinding, and no concrete effects had occurred	Not ripe: issues are fit for administrative resolution first and withholding review causes no hardship
Timeliness of ZCV appeal	Appellants contended they timely appealed shortly after notice	JCFT argued appeal was untimely	Court did not reach merits because lack of standing and ripeness resolved the case (Board had also found untimeliness)

Price v. State ex rel. Wyo. Dep't of Workforce Servs., 388 P.3d 786 (Wyo. 2017) (standard of review for agency appeals).
Apodaca v. Safeway, 346 P.3d 21 (Wyo. 2015) (standing and subject-matter jurisdiction are questions of law).
Northfork Citizens for Responsible Dev. v. Park Cty. Bd. of Cty. Comm’rs, 189 P.3d 260 (Wyo. 2008) (standing in land-use context).
Hoke v. Moyer, 865 P.2d 624 (Wyo. 1993) (aggrieved party must allege perceptible harm).
L Slash X Cattle Co., Inc. v. Texaco, Inc., 623 P.2d 764 (Wyo. 1981) (interest to appeal must be substantial, immediate, and pecuniary).
Wyodak Res. Dev. Corp. v. Dep’t of Revenue, 387 P.3d 725 (Wyo. 2017) (ripeness doctrine and two-part ripeness inquiry).
Jacobs v. State ex rel. Wyo. Workers’ Safety & Comp. Div., 100 P.3d 848 (Wyo. 2004) (ripeness and prejudice from withholding review).
Abbott Laboratories v. Gardner, 387 U.S. 136 (U.S. 1967) (federal ripeness framework cited for fitness and hardship analysis).