Purcella v. Purcella, 258 P.3d 730

Burt Purcella established the Purcella Family Trust and funded it with assets including a 50% Stor‑A‑Way stock interest; he served as trustee and named Wife and Children as successor trustees.
Upon his death, remaining trust assets were divided into the Purcella Family Trust (Children as beneficiaries) and the Purcella Marital Trust (Wife as income beneficiary, Children as remainder beneficiaries).
Disputes arose post‑death between Wife and Children; Children sued alleging Wife breached fiduciary duties by depositing Marital Trust funds from Stor‑A‑Way into her personal account.
A district court summary judgment enjoined deposits into personal accounts, and held 87.05% of Stor‑A‑Way income was allocated to the Marital Trust and distributable to Wife.
The Trust Funding Agreement (signed Dec. 31, 2007) stated 87.05% of Stor‑A‑Way stock would fund the Marital and Family Trusts, with contingent distribution rules and a method for treating net proceeds and distributions if Stor‑A‑Way was sold or not sold.
On appeal, the Wyoming Supreme Court held Wife is entitled to the Marital Trust income less expenses, i.e., net income, not all income.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 'all income' vs 'net income' governs distributions to Wife	Children: intended net income only; did not change net‑income distribution.	Wife: Trust Funding Agreement clarified entitlement to all income from Stor‑A‑Way for Marital Trust.	Wife entitled to net income after expenses; not all income.
Effect of Trust Funding Agreement on original net income distributions	Agreement clarifies, not changes, net income distributions to Wife.	Agreement alters distributions to Wife to receive all income from the Marital Trust.	Agreement does not change net‑income framework; Wife gets net income.
Whether administration expenses can be deducted from Marital Trust distributions	Expenses should be deducted before distribution to Wife.	Trust administration expenses not deducted from Marital Trust income; align with original net income concept.	Trust administration expenses may be deducted; Wife receives net income.
Are Stor‑A‑Way business expenses attributable to Marital Trust distributions	Depreciation, security refunds, etc., should affect net distributions to Wife.	Stor‑A‑Way expenses are corporate and not chargeable to Marital Trust.	Stor‑A‑Way expenses are not borne by the Marital Trust; do not reduce Wife's net income.

Wells Fargo Bank Wyoming, N.A. v. Hodder, null (Wyoming Supreme Court 2006) (interpret contract terms to ascertain intent; compare provisions as a whole)
Cash v. Granite Springs Retreat Ass'n, Inc., null (Wyoming Supreme Court 2011) (de novo review of summary judgments)