Redland v. Redland, 346 P.3d 857

Background

Richard and Nellie Redland accumulated ranch lands and leases. In 1989 Robert and Irene executed the Robert & Irene Redland Family Trust naming themselves trustees and the five children as beneficiaries; the Trust contemplated adding property over time.
Over years the family operated ranching enterprises together; several deeded parcels and state/BLM leases were expected by the children to be placed into the Family Trust but were later found in Robert and Irene’s revocable trusts or conveyed to a daughter (Lisa Kimsey).
The Redland Children (four siblings) sued Robert (and Kimseys) asserting promissory estoppel and related claims to force transfer of disputed properties into the Family Trust; Robert counterclaimed in part.
On initial summary judgment the district court found statutes of frauds/limitations barred the children’ claims; this Court (Redland I) reversed and remanded for trial on those issues, finding disputed facts existed.
After a bench trial on remand the district court found Robert made repeated oral promises to place the disputed property in the Trust, that promissory estoppel rendered those promises enforceable, and that the children’s claims were not time-barred; it ordered transfer of most disputed property immediately and held Manderson Place would transfer on Robert’s death.
On appeal the Wyoming Supreme Court (this opinion) affirms the district court except it modifies the Manderson Place disposition, directing immediate transfer to the Family Trust subject to Robert’s life estate.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether enforceable oral promises existed to place disputed property into the Family Trust	Children: Oral promises and their contributions (money, labor, improvements) created enforceable obligations (promissory estoppel) separate from the written Trust	Robert: The written Trust is unambiguous and final; parol evidence cannot add terms or create obligations outside the Trust	Court: Affirmed—oral promises found enforceable under promissory estoppel as collateral/separate agreements supported by consideration and not inconsistent with Trust
Whether parol evidence could be admitted to prove separate oral agreements	Children: Extrinsic evidence proper to show separate collateral oral agreements and surrounding circumstances	Robert: Parol evidence rule bars considering evidence outside unambiguous written Trust to add terms	Court: Parol rule does not bar proof of separate collateral oral agreements; district court properly considered extrinsic evidence under established exceptions
Whether the statute of limitations barred the children’s claims	Children: Discovery rule delays accrual until they learned in 2007 that property had been diverted; suit filed 2008 was timely	Robert: Claims accrued earlier; discovery rule shouldn’t apply to contract claims here	Court: Promissory estoppel claim is subject to discovery rule; facts show plaintiffs did not know and had no reason to know of breach until 2007, so claims timely
Proper remedy for Manderson Place disposition	Children: Manderson was promised to be last trust parcel and should be placed in Trust	Robert: Court’s transfer-upon-death order effectively creates a will or improperly dictates testamentary disposition	Court: Modify order—Manderson Place must be conveyed immediately to the Family Trust but subject to Robert’s life estate terminating at his death

Key Cases Cited

Redland v. Redland, 288 P.3d 1173 (Wyo. 2012) (prior appeal reversing summary judgment and remanding statute-of-frauds/limitations issues)
Mullinnix, LLC v. HKB Royalty Trust, 126 P.3d 909 (Wyo. 2006) (parol evidence rule is substantive; extrinsic evidence may explain deed/contract terms)
Longtree, Ltd. v. Resource Control Int'l, Inc., 755 P.2d 195 (Wyo. 1988) (distinguishing partial vs. total integration and when parol evidence may supplement an incomplete writing)
Belden v. Thorkildsen, 156 P.3d 320 (Wyo. 2007) (extrinsic evidence admissible to establish separate collateral oral agreements independent of written contract)
Lefforge v. Rogers, 419 P.2d 625 (Wyo. 1966) (historical discussion of parol-evidence exceptions for collateral agreements)
Applied Genetics Int'l v. First Affiliated Securities, 912 F.2d 1238 (10th Cir. 1990) (parol-evidence exceptions when oral agreement is separate and distinct)
Carnahan v. Lewis, 273 P.3d 1065 (Wyo. 2012) (Wyoming follows the discovery rule for accrual of causes of action in property disputes)
Richardson Assocs. v. Lincoln-Devore, 806 P.2d 790 (Wyo. 1991) (discussion of discovery tolling in contract contexts and limits where no fraud/concealment alleged)
Verschoor v. Mountain W. Farm Bureau Mut. Ins. Co., 907 P.2d 1293 (Wyo. 1995) (oral promise can give rise to a separate enforceable obligation under promissory estoppel even if it does not alter written policy)