Star Valley Ranch Ass'n v. Daley, 334 P.3d 1207

Leisure Valley, Inc. developed Star Valley Ranch with 21 plats; covenants were recorded in 11 phases, covering all plats; amendments require 70% of the then-record lot owners and recording in Lincoln County.
From 2010, the Association sought to amend the eleven covenants into a single, uniform set for the entire subdivision, circulating proposed amendments to owners for approval.
1,476 lot owners approved, representing 73% subdivision-wide, but only 60% of owners in Plats 1–2 and 63% in Plat 3 approved.
Clerk refused to record the signatures as instruments; the Association filed an affidavit alleging 70% approval and the Clerk recorded the amended covenants.
Appellees sued for declaration of invalidity and injunction; district court granted summary judgment for Appellees, holding amendments failed for Plats 1–3 and were invalid as to those plats.
Court held each covenant set applies only to its listed plats; aggregate 70% across all plats does not satisfy per-plat approval; impracticability and standing issues addressed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did aggregate approval over all plats satisfy the 70% requirement for Plats 1–3?	Association: aggregate 73% subdivision-wide suffices.	Appellees: per-plat approval needed; Plats 1–3 below 70%.	Amendments invalid for Plats 1–3; per-plat approval required.
Was impracticability a valid defense to filing a written agreement?	Association: impracticable due to clerk’s refusal to record signatures.	Appellees: impracticability not; noncompliant filing defeats validity.	Impracticability defense rejected; amendments invalid regardless of clerk’s action.
Do Appellees have standing to challenge amendments affecting plats where they are not owners?	Association: lack of stake outside owned plats.	Appellees: ownership in some plats and unified challenge to whole subdivision; standing present.	Appellees have standing to challenge as to multiple plats and to challenge the amendments as a whole.

American Holidays, Inc. v. Foxtail Owners Ass’n, 821 P.2d 577 (Wy. 1991) (contract interpretation—intention and entire context control)
Bowers Welding & Hotshot, Inc. v. Bromley, 699 P.2d 299 (Wy. 1985) (contract interpretation—notice and binding covenants)
Kindler v. Anderson, 433 P.2d 268 (Wy. 1967) (interpretation of restrictions; plain meaning if unambiguous)
Arnold v. Ommen, 201 P.3d 1127 (Wy. 2009) (contract interpretation—reading provisions together)
Riverview Heights Homeowners’ Ass’n v. Rislov, 205 P.3d 1035 (Wy. 2009) (amendment by instruments executed/acknowledged requirement)
Mortenson v. Scheer, 957 P.2d 1302 (Wy. 1998) (impracticability doctrine—supervening impracticability defense)
Claman v. Popp, 279 P.3d 1003 (Wy. 2012) (contract interpretation and standing considerations)