Windsor Energy Group, L.L.C., an Oklahoma Limited Liability Company, and Windsor Beaver Creek L.L.C., a Delaware Limited Liability Company, 2014 WY 96

In 2000 Huber and Suncor entered a joint operating agreement (JOA) for Beaver Creek oil/gas leases; Huber was operator and Suncor non-operator. The JOA required monthly joint interest bills (JIBs), operator notice, AFEs for certain expenditures, and allowed non-operators two years to contest/audit JIBs; it bound successors and assigns.
Suncor assigned its interest to Dolphin in 2004; Huber assigned to Windsor the same year. Windsor began billing Dolphin in 2005; Dolphin paid nothing and later declared bankruptcy in 2008.
Windsor waited nearly two years before demanding payment from Dolphin and did not demand payment from Suncor until December 2009; Windsor sued Suncor in March 2010 for breach of the JOA seeking >$625,000 (later amended to >$900,000).
On summary judgment the district court held Suncor remained contractually liable as an assignor because it had not been expressly released; genuine issues remained on damages and laches. After a bench trial the court found Windsor’s claim barred by laches and denied recovery.
The Wyoming Supreme Court affirmed, holding (1) laches can apply in some statutory-limit contract actions, and (2) on these facts Windsor’s long delay, failure to produce underlying documentation, and resulting prejudice to Suncor satisfied laches.

Issue	Plaintiff's Argument (Windsor)	Defendant's Argument (Suncor)	Held
Whether laches is available to bar a breach-of-contract claim governed by a statute of limitations	Laches is inapplicable where a statute of limitations applies; Windsor sued within the ten‑year period	Laches may bar the claim because equitable considerations (delay + prejudice) can make enforcement unfair despite an unexpired statute	Court: Laches may, in limited circumstances, be a defense to an action at law governed by a statute of limitations; available but its use is narrow
Whether the district court abused its discretion in finding laches (inexcusable delay and prejudice)	Delay was excusable or irrelevant because obligations and audit rights ran to the assignee (Dolphin); Windsor complied with JOA obligations by billing the then-non-operator	Windsor unreasonably delayed (5+ years to notify Suncor; 7 years to produce JIBs); destroyed/failed to produce underlying docs; Suncor was prejudiced (lost audit rights, lost subrogation/indemnity, witnesses/docs)	Court: No abuse of discretion; findings not clearly erroneous — Windsor’s undue delay and prejudice to Suncor satisfy laches and bar recovery

Moncrief v. Sohio Petroleum Co., 775 P.2d 1021 (Wyo. 1989) (recognizes laches as especially apt in oil and gas disputes because of volatile values)
Dorsett v. Moore, 61 P.3d 1221 (Wyo. 2003) (defines laches as delay that disadvantages another)
Ultra Resources, Inc. v. Hartman, 226 P.3d 889 (Wyo. 2010) (discusses equitable defenses and difficulty of establishing laches)
Anderson v. Wyoming Development Co., 154 P.2d 318 (Wyo. 1944) (applied laches to bar a breach-of-contract claim)
Eblen v. Eblen, 234 P.2d 434 (Wyo. 1951) (equity may refuse relief after undue delay; laches complements statutes of limitation)
Glenrock v. Abadie, 259 P.2d 766 (Wyo. 1953) (statutes of limitation apply broadly after fusion of law and equity)
Hammond v. Hammond, 14 P.3d 199 (Wyo. 2000) (distinguishes child support enforcement where laches was inapplicable)
Continental Sheep Co. v. Woodhouse, 256 P.2d 97 (Wyo. 1953) (addresses adverse inference/spoliation when a party fails to preserve original documentation)