Wyoming Statutes
Wyo. Stat. § 1-21-1208 (2026)
Deductions from deposit; written itemization;
✓ current as of May 2026
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time limits; failure to give notice; recovery by renter;
utilities deposit; penalty.
(a) Upon termination of the rental agreement, property or
money held as a deposit may be applied by the owner or his agent
to the payment of accrued rent, damages to the residential
rental unit beyond reasonable wear and tear, the cost to clean
the unit to the condition at the beginning of the rental
agreement and to other costs provided by any contract. The
balance of any deposit and prepaid rent and a written
itemization of any deductions from the deposit together with
reasons therefor, shall be delivered or mailed without interest
to the renter within thirty (30) days after termination of the
rental agreement or within fifteen (15) days after receipt of
the renter's new mailing address, whichever is later. If there
is damage to the residential rental unit, this period shall be
extended by thirty (30) days. The renter shall within thirty
(30) days of termination of the rental agreement, notify the
owner or designated agent of the location where payment and
notice may be made or mailed.
(b) After termination of the rental agreement, property or
money held and separately identified as a utilities deposit
shall be refunded by the owner to the renter within ten (10)
days of a satisfactory showing that all utility charges incurred
by the renter have been paid. Absent such showing within forty-
five (45) days of termination, the owner shall within fifteen
(15) days thereafter, apply the utilities deposit to the
outstanding utility debt incurred by the renter. Any refund due
to the renter shall be paid within seven (7) days after the
utility deposit has been applied to the renter's utility debt,
or within fifteen (15) days after receipt of the renter's new
mailing address, whichever is later.
(c) If the owner of a residential rental unit or his agent
unreasonably fails to comply with subsection (a) or (b) of this
section, the renter may recover the full deposit and court
costs. In an action by a renter pursuant to this section, if the
owner is the prevailing party and the court finds the renter
acted unreasonably in bringing the action, the owner may be
awarded court costs in addition to any other relief available.Notes of Decisions
Cited in 3
cases, 2004–2015 · leading case: Merrill v. Jansma, 86 P.3d 270 (Wyo. 2004).
Merrill v. Jansma, 86 P.3d 270 (Wyo. 2004). “If the rental agreement is terminated, the rent paid shall be prorated to the date the renter vacates the unit and any balance shall be refunded to the renter along with any deposit due in accordance with W.S. 1-21-1208. (e) The owner is not liable under this article for claims…”
Younker v. Inv. Realty, Inc., 461 S.W.3d 1 (Mo. Ct. App. 2015). “Code § 37-6A-2(b)(5), Wyo. Stat. Ann. § 1-21-1208 (a), Wisc. Stat.”
Michael Younker, Brad Neckermann, Adam Chadek, & Amanda Chadek v. Inv. Realty, Inc., Michael Woessner, Linda Woessner, Curtis D. Baxter, Sarah Baxter, & Williamsburg Apts., Inc., Defendants-respondents. (Mo. Ct. App. 2015). “Code § 37-6A-2(b)(5), Wyo. Stat. Ann. § 1-21-1208 (a), Wisc. Stat.”
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