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19 Wyoming opinions name it 1 courts 1939–2025 3 in the last five years
The cases below were cited by Wyoming courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Dorsett v. Mooregreen2 sentences2012"Laches is defined as such delay in enfore-ing one's rights that it works to the disadvantage of another." Dorsett v. Moore, 2003 WY 7, ¶ 9 , 61 P.3d 1221, 1224 (Wyo.2003). 2012"Laches is defined as such delay in enfore-ing one's rights that it works to the disadvantage of another." Dorsett v. Moore, 2003 WY 7, ¶ 9 , 61 P.3d 1221, 1224 (Wyo.2003). | 2 | 2 |
Moncrief v. Sohio Petroleum Co.green2 sentences2025See id. (citations omitted). 2010Moncrief, 775 P.2d at 1025 . [¶ 124] The district court ruled that the doctrine of laches does not apply to an action at law for breach of contract and cited Hammond for that statement. | 1 | 5 |
Hammond v. Hammondgreen2 sentences2025Appellants Failed to Prove Injury, Prejudice or Disadvantage [¶43] “[T]he crux of a laches defense is a party’s detrimental reliance on another’s delay.” Winney v. Jerup, 2023 WY 113, ¶ 20 , 539 P.3d 77 , 83 (Wyo. 2023) (Winney II) (citing Tram Tower Townhouse Ass’n, 2022 WY 58, ¶ 50 , 509 P.3d at 368). “[T]he party asserting the doctrine of laches must show that he relied upon the plaintiff’s actions and changed his position in reliance thereon to his prejudice.” Tram Tower Townhouse Ass’n, ¶ 50, 509 P.3d at 368 (quoting Hammond v. Hammond, 14 P.3d 199, 201 (Wyo. 2000)). [¶44] The Schroths as 2010In Hammond we ruled that laches did not apply to "child support collection actions because suits for monetary judgments for child support arrearages are legal rather than equitable." Hammond, 14 P.3d at 202 . | 1 | 2 |
Advanced Cardiovascular Systems, Inc., Plaintiff/cross-Complaint v. Scimed Life Systems, Inc., and Robert L. Hess, Cross-Complainant/appellantgreen1 sentence2024“Laches, in legal significance, is not mere delay, but delay that works a disadvantage to another.” Rodriguez-Aguirre, 264 F.3d at 1208 . [¶12] Because of the fact-dependent nature of a laches defense, “[t]he strictures of Rule 12(b)(6), wherein dismissal of the claim is based solely on the complainant’s pleading, are not readily applicable to [its] determination[.]” Advanced Cardiovascular Sys., Inc. v. Scimed Life Sys., Inc., 988 F.2d 1157, 1161 (Fed. | 1 | 1 |
Windsor Energy Group, L.L.C., an Oklahoma Limited Liability Company, and Windsor Beaver Creek L.L.C., a Delaware Limited Liability Companygreen2 sentences2015Windsor Energy Group, LLC v. Noble Energy, Inc., 2014 WY 96, ¶ 23 , 330 P.3d 285, 291-92 (Wyo.2014) (discussing stan *262 dard of review applicable to the district court's decision after a bench trial on a claim based upon the equitable doctrine of laches). [¶30] The cireuit court and, to some extent, the parties focused on the notice portion of the fourth element of unjust enrichment at trial, ie., whether EWS reasonably notified Bishop Construction and Ms. Fraser that EWS expected to be paid by them,. 2015Windsor Energy Group, LLC v. Noble Energy, Inc., 2014 WY 96, ¶ 23 , 330 P.3d 285, 291-92 (Wyo.2014) (discussing stan *262 dard of review applicable to the district court's decision after a bench trial on a claim based upon the equitable doctrine of laches). [¶30] The cireuit court and, to some extent, the parties focused on the notice portion of the fourth element of unjust enrichment at trial, ie., whether EWS reasonably notified Bishop Construction and Ms. Fraser that EWS expected to be paid by them,. | 1 | 1 |
John P. Saad & Sons, Inc. v. Nashville Thermal Transfer Corp.green1 sentence2014See, eg., Wyler Summit P'ship v. Turner Broadcasting Syst., 235 F.3d 1184 (9th Cir.2000) (laches is not a defense to a breach of contract claim); Dep't of Banking & Finance of the State of Nebraska v. Wilken, 217 Neb. 796 , 352 N.W.2d 145 (1984) (laches is available in a limited scope as a defense to an action at law based on contract); John P. Saad & Sons, Inc. v. Nashville Thermal Transfer Corp. 715 S.W.2d 41, 46-47 (Tenn.1986) (laches barred claim for breach of contract to deliver waste oil). | 1 | 1 |
Wyler Summit Partnership, a Partnership v. Turner Broadcasting System, Inc., a Georgia Corporation Turner Entertainment Co., a Georgia Corporationgreen1 sentence2014See, eg., Wyler Summit P'ship v. Turner Broadcasting Syst., 235 F.3d 1184 (9th Cir.2000) (laches is not a defense to a breach of contract claim); Dep't of Banking & Finance of the State of Nebraska v. Wilken, 217 Neb. 796 , 352 N.W.2d 145 (1984) (laches is available in a limited scope as a defense to an action at law based on contract); John P. Saad & Sons, Inc. v. Nashville Thermal Transfer Corp. 715 S.W.2d 41, 46-47 (Tenn.1986) (laches barred claim for breach of contract to deliver waste oil). | 1 | 1 |
Cole v. State Ex Rel. Browngreen2 sentences2004Brown, 2002 MT 32 , 308 Mont. 265 , 42 P.3d 760, 762 (Mont.2002), wherein the Montana Supreme Court applied the doctrine of laches to bar two state legislators and two electors from challenging that state’s term limit law nine years after it was enacted by initiative. [¶ 15] The appellants counter these arguments by reminding this Court that laches has historically been reserved “for those rare cases where a protracted acquiescence by plaintiff induces a defendant to undertake substantial activities in reliance on the acquiescence.” First Nat. 2004Brown, 2002 MT 32 , 308 Mont. 265 , 42 P.3d 760, 762 (Mont.2002), wherein the Montana Supreme Court applied the doctrine of laches to bar two state legislators and two electors from challenging that state’s term limit law nine years after it was enacted by initiative. [¶ 15] The appellants counter these arguments by reminding this Court that laches has historically been reserved “for those rare cases where a protracted acquiescence by plaintiff induces a defendant to undertake substantial activities in reliance on the acquiescence.” First Nat. | 1 | 1 |
First National Bank of Lander v. First Wyoming Savings & Loan Ass'ngreen1 sentence2004Bank of Lander v. First Wyoming Sav. and Loan Ass’n, 592 P.2d 697, 702 (Wyo.1979). | 1 | 1 |
Squaw Mountain Cattle Co. v. Bowengreen1 sentence2003Thompson v. Board of County Commissioners of the County of Sublette, 2001 WY 108, ¶ 6 , 34 P.3d 278, ¶ 6 , (Wyo.2001); Goshen Irrigation District v. Wyoming State Board of Control, 926 P.2d 943, 949 (Wyo.1996); Squaw Mountain Cattle Company v. Bowen, 804 P.2d 1292, 1297 (Wyo.1991). | 1 | 1 |
Goshen Irrigation District v. Wyoming State Board of Controlgreen1 sentence2003Thompson v. Board of County Commissioners of the County of Sublette, 2001 WY 108, ¶ 6 , 34 P.3d 278, ¶ 6 , (Wyo.2001); Goshen Irrigation District v. Wyoming State Board of Control, 926 P.2d 943, 949 (Wyo.1996); Squaw Mountain Cattle Company v. Bowen, 804 P.2d 1292, 1297 (Wyo.1991). | 1 | 1 |
Morad v. Browngreen1 sentence2003We have no difficulty finding sufficient prejudice on the face of the Stutz-mans’ petition to warrant application of the doctrine of laches to bar their claims. [¶ 56] The Stutzmans argue that the application of laches is inappropriate in cases involving “legal title.” While that may be the general rule, see Morad v. Brown, 549 P.2d 312, 317 (Wyo.1976), this case does not involve legal title in the usual sense, but concerns instead the question of who controls the water stored under adjudicated reservoir permits. | 1 | 1 |
State ex inf. Crow v. West Side Street Railway Co.green2 sentences2002Crow v. West Side Street Railway Company, 146 Mo. 155 , 47 S.W. 959, 961 (1898)). [¶ 27] In addition to suggesting an interpretation of the statutes which would prohibit amended production reports and refund requests after the time limit for appeals, DOR argues we should reach the same result on the basis of the doctrine of laches. 2002Crow v. West Side Street Railway Company, 146 Mo. 155 , 47 S.W. 959, 961 (1898)). [¶ 27] In addition to suggesting an interpretation of the statutes which would prohibit amended production reports and refund requests after the time limit for appeals, DOR argues we should reach the same result on the basis of the doctrine of laches. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Wyoming. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Tram Tower Townhouse Association v. Beryl Weiner and Leonard Dvorson Neal Norman and Melissa Norman, as Trustees of the Norman Holdings Trust Under Agreement Dated July 12, 2005 Aconcagua Capital, Llc Cliff Bruder Ann Bruder Margaret Armstrong James A. Krentler, as Trustee of the James Krentler Trust Under Agreement Dated April 8, 1987 Frank Perna, Jr. A/K/A Frank Perna John L. Kemmerer, Iii Constance Kemmerer and Michael Healy
green
1 sentence2025Appellants Failed to Prove Injury, Prejudice or Disadvantage [¶43] “[T]he crux of a laches defense is a party’s detrimental reliance on another’s delay.” Winney v. Jerup, 2023 WY 113, ¶ 20 , 539 P.3d 77 , 83 (Wyo. 2023) (Winney II) (citing Tram Tower Townhouse Ass’n, 2022 WY 58, ¶ 50 , 509 P.3d at 368). “[T]he party asserting the doctrine of laches must show that he relied upon the plaintiff’s actions and changed his position in reliance thereon to his prejudice.” Tram Tower Townhouse Ass’n, ¶ 50, 509 P.3d at 368 (quoting Hammond v. Hammond, 14 P.3d 199, 201 (Wyo. 2000)). [¶44] The Schroths as | 1 | 2025–2025 |
Robert E. James and Naomi R. James v. Gerald C. James and Gladys M. Winkel
green
1 sentence2025Rafter J., 2024 WY 114 ¶ 17 , 558 P.3d at 569 (quoting Gumpel, 2017 WY 46, ¶ 24 , 393 P.3d at 1289 ); James v. James, 2021 WY 96, ¶ 23 , 493 P.3d 1258 , 1264 (Wyo. 2021). | 1 | 2025–2025 |
J. William Winney, Jr. v. Michael Troy Jerup
green
2 sentences2025Appellants Failed to Prove Injury, Prejudice or Disadvantage [¶43] “[T]he crux of a laches defense is a party’s detrimental reliance on another’s delay.” Winney v. Jerup, 2023 WY 113, ¶ 20 , 539 P.3d 77 , 83 (Wyo. 2023) (Winney II) (citing Tram Tower Townhouse Ass’n, 2022 WY 58, ¶ 50 , 509 P.3d at 368). “[T]he party asserting the doctrine of laches must show that he relied upon the plaintiff’s actions and changed his position in reliance thereon to his prejudice.” Tram Tower Townhouse Ass’n, ¶ 50, 509 P.3d at 368 (quoting Hammond v. Hammond, 14 P.3d 199, 201 (Wyo. 2000)). [¶44] The Schroths as 2025Appellants Failed to Prove Injury, Prejudice or Disadvantage [¶43] “[T]he crux of a laches defense is a party’s detrimental reliance on another’s delay.” Winney v. Jerup, 2023 WY 113, ¶ 20 , 539 P.3d 77 , 83 (Wyo. 2023) (Winney II) (citing Tram Tower Townhouse Ass’n, 2022 WY 58, ¶ 50 , 509 P.3d at 368). “[T]he party asserting the doctrine of laches must show that he relied upon the plaintiff’s actions and changed his position in reliance thereon to his prejudice.” Tram Tower Townhouse Ass’n, ¶ 50, 509 P.3d at 368 (quoting Hammond v. Hammond, 14 P.3d 199, 201 (Wyo. 2000)). [¶44] The Schroths as | 1 | 2025–2025 |
Rafter J Ranch Homeowner's Association, a Wyoming Nonprofit Corporation v. Stage Stop, Inc., a Wyoming Profit Corporation
green
2 sentences2025Rafter J., 2024 WY 114 ¶ 17 , 558 P.3d at 569 (quoting Gumpel, 2017 WY 46, ¶ 24 , 393 P.3d at 1289 ); James v. James, 2021 WY 96, ¶ 23 , 493 P.3d 1258 , 1264 (Wyo. 2021). 2025Rafter J., 2024 WY 114 ¶ 17 , 558 P.3d at 569 (quoting Gumpel, 2017 WY 46, ¶ 24 , 393 P.3d at 1289 ); James v. James, 2021 WY 96, ¶ 23 , 493 P.3d 1258 , 1264 (Wyo. 2021). | 1 | 2025–2025 |
Glenn J. Gumpel and Merrily Gumpel, Trustees of the Glenn and Merrily Gumpel Family Trust Dated October 8, 2001 v. Copperleaf Homeowners Association, Inc., a Wyoming Non-Profit Corporation Roderick Fuller and Kathleen A. Fuller, Trustees of the Roderick and Kathleen Fuller Family Trust Dated January 16, 1997 Mooncrest Ranch A/K/A Mooncrest Ranch, Inc., a Wyoming Corporation Successor By Merger To Rocking M Ranch, Inc. and Wells Fargo Bank, N.A.
green
2 sentences2025Rafter J., 2024 WY 114 ¶ 17 , 558 P.3d at 569 (quoting Gumpel, 2017 WY 46, ¶ 24 , 393 P.3d at 1289 ); James v. James, 2021 WY 96, ¶ 23 , 493 P.3d 1258 , 1264 (Wyo. 2021). 2025Rafter J., 2024 WY 114 ¶ 17 , 558 P.3d at 569 (quoting Gumpel, 2017 WY 46, ¶ 24 , 393 P.3d at 1289 ); James v. James, 2021 WY 96, ¶ 23 , 493 P.3d 1258 , 1264 (Wyo. 2021). | 1 | 2025–2025 |
United States v. Rodriguez-Aguirre
green
1 sentence2024“Laches, in legal significance, is not mere delay, but delay that works a disadvantage to another.” Rodriguez-Aguirre, 264 F.3d at 1208 . [¶12] Because of the fact-dependent nature of a laches defense, “[t]he strictures of Rule 12(b)(6), wherein dismissal of the claim is based solely on the complainant’s pleading, are not readily applicable to [its] determination[.]” Advanced Cardiovascular Sys., Inc. v. Scimed Life Sys., Inc., 988 F.2d 1157, 1161 (Fed. | 1 | 2024–2024 |
Potash Co. of America v. International Minerals & Chemical Corp.
green
1 sentence2022When “the party which advances the defense of laches is responsible for the delay or contributes substantially to it he cannot take advantage of it.” Pelt, 611 F. Supp. 2d at 1286 (quoting Potash, 213 F.2d at 155 ). | 1 | 2022–2022 |
Pelt v. Utah
green
1 sentence2022When “the party which advances the defense of laches is responsible for the delay or contributes substantially to it he cannot take advantage of it.” Pelt, 611 F. Supp. 2d at 1286 (quoting Potash, 213 F.2d at 155 ). | 1 | 2022–2022 |
Bliler v. Boswell
green
1 sentence2014Id. | 1 | 2014–2014 |
Ultra Resources, Inc. v. Hartman
green
1 sentence2014Seq, e.g., Ultra Resources, ¶¶ 123-28, 226 P.3d at 929-30 ; Goshen Irrigation Distr. v. Wyo. | 1 | 2014–2014 |
DEPT. OF BANKING & FINANCE OF STATE v. Wilken
green
2 sentences2014See, eg., Wyler Summit P'ship v. Turner Broadcasting Syst., 235 F.3d 1184 (9th Cir.2000) (laches is not a defense to a breach of contract claim); Dep't of Banking & Finance of the State of Nebraska v. Wilken, 217 Neb. 796 , 352 N.W.2d 145 (1984) (laches is available in a limited scope as a defense to an action at law based on contract); John P. Saad & Sons, Inc. v. Nashville Thermal Transfer Corp. 715 S.W.2d 41, 46-47 (Tenn.1986) (laches barred claim for breach of contract to deliver waste oil). 2014See, eg., Wyler Summit P'ship v. Turner Broadcasting Syst., 235 F.3d 1184 (9th Cir.2000) (laches is not a defense to a breach of contract claim); Dep't of Banking & Finance of the State of Nebraska v. Wilken, 217 Neb. 796 , 352 N.W.2d 145 (1984) (laches is available in a limited scope as a defense to an action at law based on contract); John P. Saad & Sons, Inc. v. Nashville Thermal Transfer Corp. 715 S.W.2d 41, 46-47 (Tenn.1986) (laches barred claim for breach of contract to deliver waste oil). | 1 | 2014–2014 |
Cole v. State Ex Rel. Brown
green
1 sentence2004Brown, 2002 MT 32 , 308 Mont. 265 , 42 P.3d 760, 762 (Mont.2002), wherein the Montana Supreme Court applied the doctrine of laches to bar two state legislators and two electors from challenging that state’s term limit law nine years after it was enacted by initiative. [¶ 15] The appellants counter these arguments by reminding this Court that laches has historically been reserved “for those rare cases where a protracted acquiescence by plaintiff induces a defendant to undertake substantial activities in reliance on the acquiescence.” First Nat. | 1 | 2004–2004 |
Anderson v. Wyoming Development Co.
green
2 sentences2003Id. at 490 , 154 P.2d 318 . [¶ 58] We hold the district court properly found the Stutzmans’ petition was also barred by the doctrine of laches. 2003Id. at 490 , 154 P.2d 318 . [¶ 58] We hold the district court properly found the Stutzmans’ petition was also barred by the doctrine of laches. | 1 | 2003–2003 |
Thompson v. Bd. of Cty. Com'rs of Sublette
green
2 sentences2003Thompson v. Board of County Commissioners of the County of Sublette, 2001 WY 108, ¶ 6 , 34 P.3d 278, ¶ 6 , (Wyo.2001); Goshen Irrigation District v. Wyoming State Board of Control, 926 P.2d 943, 949 (Wyo.1996); Squaw Mountain Cattle Company v. Bowen, 804 P.2d 1292, 1297 (Wyo.1991). 2003Thompson v. Board of County Commissioners of the County of Sublette, 2001 WY 108, ¶ 6 , 34 P.3d 278, ¶ 6 , (Wyo.2001); Goshen Irrigation District v. Wyoming State Board of Control, 926 P.2d 943, 949 (Wyo.1996); Squaw Mountain Cattle Company v. Bowen, 804 P.2d 1292, 1297 (Wyo.1991). | 1 | 2003–2003 |
Patterson v. Hewitt
green
2 sentences1989Regarding laches, we quoted Patterson, 195 U.S. at 317 , 25 S.Ct. at 36 , to the effect that, in addition to the passage of time, a change in the value of the property was a material consideration in application of the doctrine of laches. 1989Regarding laches, we quoted Patterson, 195 U.S. at 317 , 25 S.Ct. at 36 , to the effect that, in addition to the passage of time, a change in the value of the property was a material consideration in application of the doctrine of laches. | 1 | 1989–1989 |
Park County Resource Council, Inc. v. United States Department Of Agriculture
green
2 sentences1989Park County Resource Council, Inc., 817 F.2d 609 ; Moore, 553 P.2d 8 . 1989Park County Resource Council, Inc., 817 F.2d 609 ; Moore, 553 P.2d 8 . | 1 | 1989–1989 |
Moore v. State
green
2 sentences1989Park County Resource Council, Inc., 817 F.2d 609 ; Moore, 553 P.2d 8 . 1989Park County Resource Council, Inc., 817 F.2d 609 ; Moore, 553 P.2d 8 . | 1 | 1989–1989 |
| Swift v. Swift green | 1 | 1965–1965 |
| Jones v. Haines neutral | 1 | 1956–1956 |
| Hedges v. Norris neutral | 1 | 1956–1956 |
| Chase v. Chase green | 1 | 1956–1956 |
| Jackson v. Jackson neutral | 1 | 1951–1951 |
| Horse Creek Conservation District v. Lincoln Land Co. green | 1 | 1940–1940 |
| Crocker v. Dougherty neutral | 1 | 1939–1939 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.