Wyoming Statutes
Wyo. Stat. § 1-3-103 (2026)
Recovery of real property; generally.
✓ current as of May 2026
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An action for the recovery of the title or possession of lands, tenements or hereditaments can only be brought within ten (10) years after the cause of such action accrues.
Notes of Decisions
Cited in 49
cases (7 in the last 5 years), 1978–2024 · leading case: Mueller v. Hoblyn, 887 P.2d 500 (Wyo. 1994).
Mueller v. Hoblyn, 887 P.2d 500 (Wyo. 1994). “Wyo.Stat. § 1-3-103 (1988). To terminate an easement by adverse possession, the owner of the servient estate must take an action that would be permitted only if the easement did not exist.”
Dwight Lyman & Betty L. Lyman, as Individuals & as Trs. of the Dwight Lyman Living Trust Dated November 11, 2016, & Trs. of the Betty L. Lyman Living Trust Dated November 11, 2016 v. Robert B. Childs, Individually & as Tr. of the Robert B. Childs Living Trust Dated April 4, 2012, 2023 WY 16 (Wyo. 2023). “2014)); see also Wyo. Stat. Ann. § 1-3-103 (2021). An adverse claimant must have “occupied the land for the statutory period, in a manner plainly indicating that he has acted as the owner thereof .”
Louise J. Galiher, Tr. of the Louise J. Galiher Trust v. Dennis & Vicki Johnson, 2017 WY 31 (Wyo. 2017). “[1Í20] One claiming that he has adversely possessed the land of another for the ten-year period set out in Wyo. Stat. Ann. § 1-3-103 (LexisNexis 2015) must show that his use of the land was actual, open, notorious, exclusive, and continuous, and that it was hostile and pursuant…”
Gregory v. Sanders, 635 P.2d 795 (Wyo. 1981). “[4] The use must also last for at least ten years before the title or right is vested by § 1-3-103, W.S. 1977. [5] Prescriptive easements *801 are not favored in law.”
Ultra Resources, Inc. v. Hartman, 2010 WY 36 (Wyo. 2010). “[¶ 119] The defendants are somewhat imprecise about which statute of limitation governs the plaintiffs' claims, citing in turn to Wyo. Stat. Ann. §§ 1-3-103 (LexisNexis 2009) (ten year limitation period for recovery of real property); Wyo.”
Cheyenne Airport Bd. v. Rogers, 707 P.2d 717 (Wyo. 1985). “Section 1-3-103, W.S.1977, provides that an action for the recovery of title or possession of lands, tenements or hereditaments can only be brought within ten years after the cause of action accrues.”
DeWitt v. Balben, 718 P.2d 854 (Wyo. 1986). “The defendants contend the action is barred under § 1-3-103, W.S. 1977, which reads: "An action for the recovery of the title or possession of lands, tenements or hereditaments can only be brought within ten (10) years after the cause of such action accrues.”
White v. Wheeler, 406 P.3d 1241 (Wyo. 2017). “One claiming that he has adversely possessed the land of another for the ten-year period set out in Wyo. Stat. Ann. § 1-3-103 (LexisNexis 2015) must show that his use of the land was actual, open, notorious, exclusive, and continuous, and that it was hostile and pursuant to a…”
Galiher v. Johnson, 432 P.3d 502 (Wyo. 2018). “When there is no clear showing to the contrary, a person who has occupied the land for the statutory period, in a manner plainly indicating that he has acted as the owner thereof, is entitled to a presumption of adverse possession; and the burden shifts to the opposing party to…”
Finley Res., Inc. v. Ep Energy E&P Co., 443 P.3d 838 (Wyo. 2019). “1 & 2 on February 28, 2008, Plaintiff has openly, notoriously, exclusively and continuously exercised ownership and control over all of the lands covered by the Subject Leases including Subject Lease No.”
Redland v. Redland, 288 P.3d 1173 (Wyo. 2012). “Specifically, the district court found: that there is no genuine issue as to any material fact of concern to those claims for relief, that Defendant Robert Redland is entitled to judgment as a matter of law with respect to those claims for relief, that the applicable statutes of…”
Judith M. Woodward v. Thomas J. Valvoda, 2021 WY 5 (Wyo. 2021). “3d at 1233 ; Wyo. Stat. Ann. § 1-3-103 (LexisNexis 2019).”
— Wyo. Stat. § 1-3-103(1988) — 1 case
Davis v. Chadwick, 2002 WY 157 (Wyo. 2002).
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