Wyoming Statutes

Wyo. Stat. § 1-23-105 (2026)

Agreements void unless in writing.

✓ current as of May 2026

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(a) In the following cases every agreement shall be void
unless such agreement, or some note or memorandum thereof be in
writing, and subscribed by the party to be charged therewith:

          (i) Every agreement that by its terms is not to be
performed within one (1) year from the making thereof;

          (ii) Every special promise to answer for the debt,
default or miscarriage of another person;

          (iii) Every agreement, promise or undertaking made
upon consideration of marriage, except mutual promise to marry;

          (iv) Every special promise by an executor or
administrator, to answer any demand out of his own estate;

          (v) Every agreement or contract for the sale of real
estate, or the lease thereof, for more than one (1) year;

          (vi) To charge any person upon, or by reason of a
representation or assurance concerning the character, conduct,
credit, ability, trade or dealings of another, to the intent or
purpose that such other may obtain thereby, credit, money or
goods.

Notes of Decisions

Cited in 50 cases (3 in the last 5 years), 1983–2026 · leading case: Hopper v. All Pet Animal Clinic, Inc., 861 P.2d 531 (Wyo. 1993).

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Hopper v. All Pet Animal Clinic, Inc., 861 P.2d 531 (Wyo. 1993). · cites it 8× “2d at 634 ; and Wyo. Stat. § 1-23-105 (1988). The reasonableness of a covenant not to compete is assessed based upon the facts of the particular case and a review of all of the circumstances.”

Lavoie v. Safecare Health Serv., Inc., 840 P.2d 239 (Wyo. 1992). · cites it 8× “In granting summary judgment for Safecare, the trial court held that the alleged oral three-year contract was void under Wyo.Stat. § 1-23-105 (1988), the statute of frauds, because there was no writing signed by Safecare, the party to be charged.”

Wilder v. Cody Country Chamber of Com., 868 P.2d 211 (Wyo. 1994). · cites it 4× “*218 First, performance under a contract of definite duration is within the statute of frauds, Wyo.Stat. § 1-23-105 (1988), making evidence of a writing necessary if the terms are not performed within one year.”

In Re Est. of Maycock, 2001 WY 103 (Wyo. 2001). · cites it 5× “- Should the Wyoming Supreme Court create a new special exception in this jurisdiction to the statute of frauds? Deborra's statement of the issue is a bit more succinet: Does the statute of frauds, Wyo. Stat. § 1-23-105 (1999) render void the subject settlement agreement reached…”

Jerry K. Davis v. Harmony Dev., LLC, 2020 WY 39 (Wyo. 2020). · cites it 4× “” Wyo. Stat. Ann. § 1-23-105 (a)(v) (LexisNexis 2019); see also Linton v.”

Parkhurst v. Boykin, 2004 WY 90 (Wyo. 2004). · cites it 3× “4 In so doing, the district court applied the statute of frauds, Wyo. Stat. Ann. § 1-23-105 (LexisNexis 2003), which provides: § 1-23-105.”

Metz Beverage Co. v. Wyoming Beverages, Inc., 2002 WY 21 (Wyo. 2002). · cites it 2× “[T¥16] Wyoming Beverage also relies on the general statute of frauds, Wyo. Stat. Ann. § 1-23-105 (LexisNexis 2001), which states: (a) In the following cases every agreement shall be void unless such agreement, or some note or memorandum thereof be in writing, and subscribed by…”

WERCS v. Capshaw, 2004 WY 86 (Wyo. 2004). · cites it 6× “Arguing in the alternative, WERCS contended that, even assuming Capshaw's employment was of five years definite duration, and not of indefinite duration as WERCS' asserted, a provision of Wyoming's statute of frauds, Wyo. Stat. Ann. § 1-23-105 (a)(i), required a writing signed…”

Birt v. Wells Fargo Home Mortg., Inc., 2003 WY 102 (Wyo. 2003). · cites it 2× “Stature or Fraups [122] Wyo. Stat. Ann. § 1-23-105 (LexisNexis 2003) provides, in pertinent part: (a) In the following cases every agreement shall be void unless such agreement, or some note or memorandum thereof be in writing, and subscribed by the party to be charged…”

Davison v. Wyoming Game & Fish Com'n, 2010 WY 121 (Wyo. 2010). · cites it 4× “At oral argument, the [Landowners] argued that the written easement agreement could not be changed by an oral agreement.”

Cordova v. Gosar, 719 P.2d 625 (Wyo. 1986). · cites it 2× “§ 1-23-105, W.S. 1977. It follows for me that Elmer Cordova's recitation in his affidavit of a lease arrangement for a term in excess of a year that is not in writing is not competent evidence.”

Richardson v. Schaub, 796 P.2d 1304 (Wyo. 1990). · cites it 5× “W.S. 1-23-105 (Statute of Frauds) prohibits use of the "evidence" relied upon by the majority.”

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— Wyo. Stat. § 1-23-105(a) — 3 cases

Ames v. Sundance State Bank, 850 P.2d 607 (Wyo. 1993).

Catherine Meyer, as Beneficiary of the 1999 Carlsen Fam. Living Trust, 2014 WY 91 (Wyo. 2014).

Sievers v. Barton Ex Rel. Est. of Barton, 775 P.2d 489 (Wyo. 1989).

— Wyo. Stat. § 1-23-105(a)(i) — 2 cases

James Tallichet v. Jackson Hole Cmty. Radio, Inc., A/K/A "Khol", a Wyoming Nonprofit Corp., 2026 WY 56 (Wyo. 2026).

Michael Scott Hughes v. The State of Wyoming, 2026 WY 66 (Wyo. 2026).

— Wyo. Stat. § 1-23-105(a)(v) — 1 case

Redland v. Redland, 288 P.3d 1173 (Wyo. 2012).

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