American rule in Wyoming

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2016“Attorney fees are recoverable under the American rule only where a contractual or statutory provision authorizes such recovery, or as a form of punitive damages when such damages can properly be awarded.” Positive Progressions, 2015 WY 138 , ¶ 29, 360 P.3d at 1016 (citing Alexander v. Meduna, 2002 WY 83, ¶ 49 , 47 P.3d 206, 220-21 (Wyo. 2002); Olds v. Hosford, 354 P.2d 947, 950 (Wyo. 1960)). 16 *764 [¶85] The Uniform Trust Code authorizes the payment of attorney fees and costs: In a judicial proceeding involving the administration of a trust, the court, as justice and equity may require, may

2016“Attorney fees are recoverable under the American rule only where a contractual or statutory provision authorizes such recovery, or as a form of punitive damages when such damages can properly be awarded.” Positive Progressions, 2015 WY 138 , ¶ 29, 360 P.3d at 1016 (citing Alexander v. Meduna, 2002 WY 83, ¶ 49 , 47 P.3d 206, 220-21 (Wyo. 2002); Olds v. Hosford, 354 P.2d 947, 950 (Wyo. 1960)). 16 *764 [¶85] The Uniform Trust Code authorizes the payment of attorney fees and costs: In a judicial proceeding involving the administration of a trust, the court, as justice and equity may require, may

2017Appellants filed this timely appeal. *208 DISCUSSION [¶6] Wyoming subscribes to ' the American rule on recovery of attorney fees, under which “each party is generally responsible for his own attorney fees.” Alexander v. Meduna, 2002 WY 83, ¶ 49 , 47 P.3d 206, 220 (Wyo. 2002).

2017Appellants filed this timely appeal. *208 DISCUSSION [¶6] Wyoming subscribes to ' the American rule on recovery of attorney fees, under which “each party is generally responsible for his own attorney fees.” Alexander v. Meduna, 2002 WY 83, ¶ 49 , 47 P.3d 206, 220 (Wyo. 2002).

2015Evans v. Moyer, 2012 WY 111, ¶ 37 , 282 P.3d 1203, 1214 (Wyo.2012). [T24] "Although Wyoming generally subscribes to the American rule regarding the recovery of attorney's fees, under which rule each party pays his or her own fees, a prevailing party may be reimbursed for attorney's fees when provided for by contract or statute." Weiss v. Weiss, 2009 WY 124, ¶ 8 , 217 P.3d 408, 410-11 (Wyo.2009) (citing Forshee v. Delaney, 2005 WY 103, ¶ 7 , 118 P.3d 445, 448 (Wyo.2005)). [T25] The primary question presented in WCR's appeal is whether the district court had the statutory authority to award Go-o

2015Evans v. Moyer, 2012 WY 111, ¶ 37 , 282 P.3d 1203, 1214 (Wyo.2012). [T24] "Although Wyoming generally subscribes to the American rule regarding the recovery of attorney's fees, under which rule each party pays his or her own fees, a prevailing party may be reimbursed for attorney's fees when provided for by contract or statute." Weiss v. Weiss, 2009 WY 124, ¶ 8 , 217 P.3d 408, 410-11 (Wyo.2009) (citing Forshee v. Delaney, 2005 WY 103, ¶ 7 , 118 P.3d 445, 448 (Wyo.2005)). [T25] The primary question presented in WCR's appeal is whether the district court had the statutory authority to award Go-o

2015Evans v. Moyer, 2012 WY 111, ¶ 37 , 282 P.3d 1203, 1214 (Wyo.2012). [T24] "Although Wyoming generally subscribes to the American rule regarding the recovery of attorney's fees, under which rule each party pays his or her own fees, a prevailing party may be reimbursed for attorney's fees when provided for by contract or statute." Weiss v. Weiss, 2009 WY 124, ¶ 8 , 217 P.3d 408, 410-11 (Wyo.2009) (citing Forshee v. Delaney, 2005 WY 103, ¶ 7 , 118 P.3d 445, 448 (Wyo.2005)). [T25] The primary question presented in WCR's appeal is whether the district court had the statutory authority to award Go-o

2015Evans v. Moyer, 2012 WY 111, ¶ 37 , 282 P.3d 1203, 1214 (Wyo.2012). [T24] "Although Wyoming generally subscribes to the American rule regarding the recovery of attorney's fees, under which rule each party pays his or her own fees, a prevailing party may be reimbursed for attorney's fees when provided for by contract or statute." Weiss v. Weiss, 2009 WY 124, ¶ 8 , 217 P.3d 408, 410-11 (Wyo.2009) (citing Forshee v. Delaney, 2005 WY 103, ¶ 7 , 118 P.3d 445, 448 (Wyo.2005)). [T25] The primary question presented in WCR's appeal is whether the district court had the statutory authority to award Go-o

2012Magin v. Solitude Homeowner's Inc., 2011 WY 102, ¶41 , 255 P.3d 920, 932 (Wyo.2011); Cline v. Rocky Mountain, Inc., 998 P.2d 946, 949 (Wyo.2000).

2011Cline v. Rocky Mountain, Inc., 998 P.2d 946, 949 (Wyo.2000).

2010Morrison v. Clay, 2006 WY 161, ¶ 16 , 149 P.3d 696, 701-02 (Wyo.2006); Schlesinger v. Woodcock, 2001 WY 120, ¶ 21 , 35 P.3d 1232, 1239 (Wyo.2001).

2010Morrison v. Clay, 2006 WY 161, ¶ 16 , 149 P.3d 696, 701-02 (Wyo.2006); Schlesinger v. Woodcock, 2001 WY 120, ¶ 21 , 35 P.3d 1232, 1239 (Wyo.2001).

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2006Citing other authorities, they further argue attorney fees are appropriate in cases where a trustee is involved in self-dealing and breaches its fiduciary duty. 76 Am.Jur.2d Trusts § 736; Hughes, 89 P.3d at 152. [¶ 58] Three years ago, in Rock Springs Land and Timber, ¶37, 75 P.3d at 628 , we reaffirmed our precedent holding the American rule applicable in this jurisdiction.

2006Citing other authorities, they further argue attorney fees are appropriate in cases where a trustee is involved in self-dealing and breaches its fiduciary duty. 76 Am.Jur.2d Trusts § 736; Hughes, 89 P.3d at 152. [¶ 58] Three years ago, in Rock Springs Land and Timber, ¶37, 75 P.3d at 628 , we reaffirmed our precedent holding the American rule applicable in this jurisdiction.

2026Relevant here, they argue that if we reverse the grant of summary judgment to the Banks on the counterclaims, the court’s award of fees and costs must also be reversed. 10 Adams & Bailey attempted to bring its arguments in the bankruptcy court when it objected to ANB’s motion to enforce the Settlement Agreement, but the bankruptcy court declined to rule on them because they did not affect the bankruptcy estate. 30 [¶79] “Generally, Wyoming subscribes to the American rule regarding recovery of attorney fees, making each party responsible for its own attorney fees, unless an award of fees is per

2026Relevant here, they argue that if we reverse the grant of summary judgment to the Banks on the counterclaims, the court’s award of fees and costs must also be reversed. 10 Adams & Bailey attempted to bring its arguments in the bankruptcy court when it objected to ANB’s motion to enforce the Settlement Agreement, but the bankruptcy court declined to rule on them because they did not affect the bankruptcy estate. 30 [¶79] “Generally, Wyoming subscribes to the American rule regarding recovery of attorney fees, making each party responsible for its own attorney fees, unless an award of fees is per

1993In UNC Teton Exploration Drilling, Inc. v. Peyton, 774 P.2d 584 (Wyo.1989), we adopted the American rule that each party in a lawsuit ordinarily shall bear his or her own attorney fees unless there is an express statutory authorization or a contractual provision to the contrary.

1993In UNC Teton Exploration Drilling, Inc. v. Peyton, 774 P.2d 584 (Wyo.1989), we adopted the American rule that each party in a lawsuit ordinarily shall bear his or her own attorney fees unless there is an express statutory authorization or a contractual provision to the contrary.

2016The final attorney fee award is, however, reviewed for abuse of discretion.” Shriners Hosps. for Children, 2016 WY 51, ¶ 102 , 373 P.3d at 417 (citations omitted). [¶84] Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.

2016The final attorney fee award is, however, reviewed for abuse of discretion.” Shriners Hosps. for Children, 2016 WY 51, ¶ 102 , 373 P.3d at 417 (citations omitted). [¶84] Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.

2015Evans v. Moyer, 2012 WY 111, ¶ 37 , 282 P.3d 1203, 1214 (Wyo.2012). [T24] "Although Wyoming generally subscribes to the American rule regarding the recovery of attorney's fees, under which rule each party pays his or her own fees, a prevailing party may be reimbursed for attorney's fees when provided for by contract or statute." Weiss v. Weiss, 2009 WY 124, ¶ 8 , 217 P.3d 408, 410-11 (Wyo.2009) (citing Forshee v. Delaney, 2005 WY 103, ¶ 7 , 118 P.3d 445, 448 (Wyo.2005)). [T25] The primary question presented in WCR's appeal is whether the district court had the statutory authority to award Go-o

2015Evans v. Moyer, 2012 WY 111, ¶ 37 , 282 P.3d 1203, 1214 (Wyo.2012). [T24] "Although Wyoming generally subscribes to the American rule regarding the recovery of attorney's fees, under which rule each party pays his or her own fees, a prevailing party may be reimbursed for attorney's fees when provided for by contract or statute." Weiss v. Weiss, 2009 WY 124, ¶ 8 , 217 P.3d 408, 410-11 (Wyo.2009) (citing Forshee v. Delaney, 2005 WY 103, ¶ 7 , 118 P.3d 445, 448 (Wyo.2005)). [T25] The primary question presented in WCR's appeal is whether the district court had the statutory authority to award Go-o

2010Claim for attorney’s fees [¶ 10] In Wyoming, “[w]e follow the American rule that each party in a lawsuit bears its own attorney’s fees in the absence of an expressed contractual or statutory provision for attorney’s fees.” McLain v. Anderson, 933 P.2d 468, 472 (Wyo.1997).

2010Claim for attorney’s fees [¶ 10] In Wyoming, “[w]e follow the American rule that each party in a lawsuit bears its own attorney’s fees in the absence of an expressed contractual or statutory provision for attorney’s fees.” McLain v. Anderson, 933 P.2d 468, 472 (Wyo.1997).

1999In Hamilton v. Town of Greybull, 942 P.2d 410, 411 (Wyo.1997), we stated: Wyoming follows the American rule that each party is normally responsible for his or her own attorney fees.

1999In Hamilton v. Town of Greybull, 942 P.2d 410, 411 (Wyo.1997), we stated: Wyoming follows the American rule that each party is normally responsible for his or her own attorney fees.

2011ANB relies on Snodgrass, 903 P.2d at 1017 , for the proposition that in the absence of a contractual provision or statutory authority a party may be awarded attorneys' fees and costs if he or she can show that "fraud, malice, oppression or willful wrong has occurred." In Snodgrass , we did note an exception to the American rule, stating that "[i]n a replevin action, a party may be awarded attorney fees when they can show that `fraud, malice, oppression or willful wrong' has occurred." 903 P.2d at 1017 (quoting Olds v. Hosford, 354 P.2d 947, 950 (Wyo.1960)).

2011ANB relies on Snodgrass, 903 P.2d at 1017 , for the proposition that in the absence of a contractual provision or statutory authority a party may be awarded attorneys' fees and costs if he or she can show that "fraud, malice, oppression or willful wrong has occurred." In Snodgrass , we did note an exception to the American rule, stating that "[i]n a replevin action, a party may be awarded attorney fees when they can show that `fraud, malice, oppression or willful wrong' has occurred." 903 P.2d at 1017 (quoting Olds v. Hosford, 354 P.2d 947, 950 (Wyo.1960)).

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2026Relevant here, they argue that if we reverse the grant of summary judgment to the Banks on the counterclaims, the court’s award of fees and costs must also be reversed. 10 Adams & Bailey attempted to bring its arguments in the bankruptcy court when it objected to ANB’s motion to enforce the Settlement Agreement, but the bankruptcy court declined to rule on them because they did not affect the bankruptcy estate. 30 [¶79] “Generally, Wyoming subscribes to the American rule regarding recovery of attorney fees, making each party responsible for its own attorney fees, unless an award of fees is per

2026Relevant here, they argue that if we reverse the grant of summary judgment to the Banks on the counterclaims, the court’s award of fees and costs must also be reversed. 10 Adams & Bailey attempted to bring its arguments in the bankruptcy court when it objected to ANB’s motion to enforce the Settlement Agreement, but the bankruptcy court declined to rule on them because they did not affect the bankruptcy estate. 30 [¶79] “Generally, Wyoming subscribes to the American rule regarding recovery of attorney fees, making each party responsible for its own attorney fees, unless an award of fees is per

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2025Bd. of Land Comm’rs v. Antelope Coal Co., 2008 WY 60, ¶ 16 , 185 P.3d 666, 670 (Wyo. 2008); Adams v. State, 2005 WY 94, ¶ 27 , 117 P.3d 1210, 1219 (Wyo. 2005); Meima v. Broemmel, 2005 WY 87, ¶ 56 , 117 P.3d 429, 447 (Wyo. 2005))). [¶45] Turning to their request for attorney fees, “Wyoming follows the American rule regarding attorney fees, which provides that each party is responsible for his or her own attorney fees.” Acorn v. Moncecchi, 2016 WY 124 , ¶ 84, 386 P.3d 739, 763 (Wyo. 2016) (citing Positive Progressions, LLC v. Landerman, 2015 WY 138, ¶ 29 , 360 P.3d 1006, 1016 (Wyo. 2015); Thorki

2023E.g., Levy v. Aspen S, LLC, 2021 WY 46, ¶ 9 , 483 P.3d 852, 856 (Wyo. 2021); Prancing Antelope I, LLC v. Saratoga Inn Overlook Homeowners Ass’n, Inc., 2021 WY 3, ¶ 65 , 478 P.3d 1171, 1187 (Wyo. 2021).

2023E.g., Levy v. Aspen S, LLC, 2021 WY 46, ¶ 9 , 483 P.3d 852, 856 (Wyo. 2021); Prancing Antelope I, LLC v. Saratoga Inn Overlook Homeowners Ass’n, Inc., 2021 WY 3, ¶ 65 , 478 P.3d 1171, 1187 (Wyo. 2021).

2023E.g., Levy v. Aspen S, LLC, 2021 WY 46, ¶ 9 , 483 P.3d 852, 856 (Wyo. 2021); Prancing Antelope I, LLC v. Saratoga Inn Overlook Homeowners Ass’n, Inc., 2021 WY 3, ¶ 65 , 478 P.3d 1171, 1187 (Wyo. 2021).

2023E.g., Levy v. Aspen S, LLC, 2021 WY 46, ¶ 9 , 483 P.3d 852, 856 (Wyo. 2021); Prancing Antelope I, LLC v. Saratoga Inn Overlook Homeowners Ass’n, Inc., 2021 WY 3, ¶ 65 , 478 P.3d 1171, 1187 (Wyo. 2021).

2020A prevailing party may, however, be reimbursed for attorney fees when provided for by contract or statute.” Douglas v. Jackson Hole Land Trust, 2020 WY 69, ¶ 20 , 464 P.3d 1223 , 1229-30 (Wyo. 2020) (quoting Thorkildsen v. Belden, 2012 WY 8, ¶ 10 , 269 P.3d 421, 424 (Wyo. 2012)). “[I]f attorney’s fees are expressly authorized by contract or statute, such provision also applies to fees incurred at the appellate level.” DeWitt v. Balben, 718 P.2d 854, 864 (Wyo. 1986).

2020A prevailing party may, however, be reimbursed for attorney fees when provided for by contract or statute.” Douglas v. Jackson Hole Land Trust, 2020 WY 69, ¶ 20 , 464 P.3d 1223 , 1229-30 (Wyo. 2020) (quoting Thorkildsen v. Belden, 2012 WY 8, ¶ 10 , 269 P.3d 421, 424 (Wyo. 2012)). “[I]f attorney’s fees are expressly authorized by contract or statute, such provision also applies to fees incurred at the appellate level.” DeWitt v. Balben, 718 P.2d 854, 864 (Wyo. 1986).