Thomas Gilcrease Foundation, as Trustee for the Gilcrease Hoback One Charitable Trust Thomas Gilcrease Foundation, as Trustee for the Gilcrease Hoback Two Charitable Trust and Thomas Gilcrease Foundation, as Trustee for the Gilcrease Hoback Three Charitable Trust v. Andy Cavallaro, sued in his Official Capacity as the Teton County Assessor, an Agency of the County of Teton, State of Wyoming, 397 P.3d 166

Thomas Gilcrease Foundation (Oklahoma nonprofit) is trustee of three Wyoming trusts owning land adjacent to Snake River; land leased to a nonprofit kayak club and reserved as open space for Teton County.
Prior assessor previously treated the properties as exempt under § 39-11-105(xix) (property of charitable trusts); after transfers to trusts, later assessors questioned whether the trusts conferred a direct benefit to Wyoming residents.
The Wyoming Attorney General advised that charitable-trust tax exemption requires benefit to members of a Wyoming community; legislature amended § 39-11-105(xix) in 2014 to require conformity with W.S. 4-10-406(a) and that the trust be "directly beneficial to the people of this state."
After the 2015 assessor requested information the Foundation did not provide, tax notices issued for 2015; Foundation paid 2010 tax previously, later contested administratively in 2011 but withdrew after assessor conceded exemption then.
Foundation filed a declaratory-judgment complaint in district court seeking a declaration that the trusts are charitable and tax-exempt under § 39-11-105(xix); the assessor moved to dismiss for failure to use administrative remedies.
District court dismissed under the primary jurisdiction doctrine (and for failure to exhaust administrative remedies); Wyoming Supreme Court affirmed, holding the Foundation should have used statutory administrative procedures and deferring factual/expert determinations to the assessor/boards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused discretion by dismissing under primary jurisdiction / for failure to exhaust administrative remedies	Foundation argued exhaustion not required because dispute involves statutory interpretation of tax-exemption for charitable trusts	Assessor argued Foundation bypassed the legislatively provided administrative review of tax assessments and must exhaust those remedies	Court held no abuse: Foundation failed to exhaust administrative remedies; even if jurisdiction existed, primary jurisdiction required deferral to administrative agency

Wyo. Dep’t of Revenue v. Exxon Mobil Corp., 150 P.3d 1216 (discretion to dismiss under primary jurisdiction/exhaustion)
Glover v. State, 860 P.2d 1169 (distinguishing exhaustion and primary jurisdiction doctrines)
Quinn Revocable Trust v. SRW, Inc., 91 P.3d 146 (agency should develop factual record first; declaratory relief limited)
Rocky Mountain Oil & Gas Ass’n v. State, 645 P.2d 1163 (when declaratory judgment proper re statute/agency rules and when it prejudges administrative issues)
City of Cheyenne v. Sims, 521 P.2d 1347 (tax-exemption determinations are factual and for administrative officers)
Memorial Hosp. of Laramie County v. Dep’t of Revenue, 770 P.2d 223 (courts should not substitute their judgment for administrative functions)