Stuart Goforth v. Jamey Fifield
2015 WY 82
| Wyo. | 2015Background
- Fifield sued Goforth for trespass on Fifield’s property and obtained damages, an injunction, and quiet title; district court entered scheduling order served via clerk’s boxes under Rule 77(d).
- Goforth’s counsel failed to file pretrial disclosures, did not attend the final pretrial conference, and offered no explanation; Fifield complied with the scheduling order.
- At trial, the court limited Goforth’s evidence to his own testimony and cross-examination of Fifield’s witnesses; Fifield presented multiple exhibits and expert testimony.
- The district court found Goforth trespassed, awarded damages (except punitive), and issued a permanent injunction; Fifield sought punitive damages but the court did not award them.
- Goforth appealed, arguing improper sanctions, potential implied easement defense, and erroneous damages; he later claimed an implied easement in a post-trial motion.
- The Wyoming Supreme Court affirmed the sanction ruling and the trespass finding, but reversed and remanded on damages related to the camper and pickup truck, ordering nominal damages instead.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the district court abuse its discretion in sanctions for pretrial noncompliance? | Goforth’s counsel ignored scheduling order; sanction was proper. | Service via clerk’s boxes violated due process; failure to hold a hearing warranted. | No abuse; sanction within court’s discretion. |
| Did Goforth prove an implied easement as a defense to trespass? | No implied easement evidence; party did not plead or prove it. | There exists an implied easement for water line and access road. | Incorrect; no implied easement proved; trespass affirmed. |
| Was the district court’s damages award for trespass correct? | Damages supported by reclamation costs and use-related losses. | Some damages (camper/truck storage) were speculative or insufficiently supported. | Affirmed for reclamation but reversed for $57,820; nominal damages awarded for pickup/truck trespass. |
Key Cases Cited
- Bratton, 2014 WY 87 (Wyo. 2014) (sanctions for failure to comply with pretrial orders within district court discretion)
- Travelers Insurance Co. v. Palmer, 714 P.2d 765 (Wyo. 1986) (dismissal for failure to appear or comply without explanation)
- Hansuld v. Lariat Diesel Corp., 2015 WY 12 (Wyo. 2015) (elements of implied easement and conduct in conveyance context)
- Miner v. Jesse & Grace, LLC, 2014 WY 17 (Wyo. 2014) (implied easement may be recognized when consistent with conveyance intentions)
- Redland v. Redland, 2015 WY 31 (Wyo. 2015) (issues raised for first time on appeal will not be considered)
- City of Kemmerer v. Wagner, 866 P.2d 1283 (Wyo. 1993) (damages measure for real property trespass; value before vs after or cost of restoration)
- Legacy Builders, LLC v. Andrews, 2014 WY 103 (Wyo. 2014) (dueling damages standards; preference for cost of restoration approach when applicable)
- Velasquez v. Chamberlain, 2009 WY 80 (Wyo. 2009) (damages for torts reviewed under clearly erroneous standard for factual findings)
- WSP, Inc. v. Wyoming Steel Fabricators & Erectors, Inc., 2007 WY 80 (Wyo. 2007) (proof standards for damages; exactness not required, but not speculative)
- Hatch v. Walton, 2015 WY 19 (Wyo. 2015) (remand for damages when record leaves court with definite conviction of error)
- Bellis v. Kersey, 2010 WY 138 (Wyo. 2010) (nominal damages available when actual damages are not shown)