Redland v. Redland
2012 WY 148
| Wyo. | 2012Background
- Consolidated appeals arise from the Redland family's dispute over trust property and related ownership interests.
- Disputes involve Manderson Place, Original Mountain Land, Woody Place, associated BLM/state leases, and the trust’s ability to hold such property.
- District court granted partial summary judgment that property claims were barred by the statute of limitations and the statute of frauds; Redland Children appeal.
- Bench trial addressed unjust enrichment claims by Rolly and Kendrick for improvements; damages awarded; counterclaims included a Redland Angus partnership claim.
- Court reverses summary judgment on property claims and remands for trial; affirms rulings on unjust enrichment and partnership claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Accrual of the statute-of-limitations period for property claims | Redland Children argue discovery-based accrual. | Redland contends accrual occurred by 1992; discovery starts later. | Disputed facts; summary judgment reversed; remand for trial. |
| Application of the statute of frauds and equitable exceptions | Full/partial performance and promissory estoppel defeat frauds defense. | Frauds apply; need factual resolution on agreements and performance. | Factual disputes preclude summary judgment; remand for trial. |
| Impact of the written conveyances vs oral agreements on property claims | Oral promises to convey all property to trust; reliance supported. | Disputes over contract interpretation and Exhibit A create ambiguity. | Remand to resolve contract interpretation versus frauds analysis. |
| Unjust enrichment and damages for improvements to trust properties | Improvements benefited Robert; promissory promises entitle reimbursement. | Challenge to causation and amount; some credibility issues. | Unjust enrichment upheld; damages awarded; affirmed. |
| Redland Angus partnership claim | Robert was a partner or entitled to partnership interest. | No partnership formed; income/tax filings were mistaken. | District court credibility determinations affirmed; no clear error. |
Key Cases Cited
- Davis v. Davis, 855 P.2d 342 (Wyo. 1993) (equitable exceptions to the statute of frauds; oral contract defense scrutinized)
- Parkhurst v. Boykin, 94 P.3d 450 (Wyo. 2004) (promissory estoppel and full/partial performance defenses to frauds)
- Hovendick v. Ruby, 10 P.3d 1119 (Wyo. 2000) (equitable tolling/exception to statute of frauds via performance)
- Fowler v. Fowler, 983 P.2d 502 (Wyo. 1997) (statute of frauds with oral promises to convey; exceptions apply)
- Carnahan v. Lewis, 273 P.3d 1067 (Wyo. 2012) (discovery rule context; surrounding circumstances determine knowledge of claim)
- Swinney v. Jones, 199 P.3d 512 (Wyo. 2008) (easement case; discovery rule focus on notice timing)
- Davis v. Davis, 855 P.2d 342 (Wyo. 1993) (repeated to emphasize frauds/exceptions significance)