Wyoming Statutes
Wyo. Stat. § 1-3-106 (2026)
When certain causes of action accrue.
✓ current as of May 2026
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A cause of action for the wrongful taking of personal property is not deemed to have accrued until the wrongdoer is discovered. A cause of action on the ground of fraud is not deemed to have accrued until the discovery of the fraud.
Notes of Decisions
Cited in 10
cases, 1985–2015 · leading case: Robert L. Kroenlein Trust ex rel. Alden v. Kirchhefer, 357 P.3d 1118 (Wyo. 2015).
Robert L. Kroenlein Trust ex rel. Alden v. Kirchhefer, 357 P.3d 1118 (Wyo. 2015). “Plaintiffs argue against application of this rule of interpretation, and in fact any rule of interpretation, contending that because the Wyo. Stat. Ann. § 1-3-106 is clear and unambiguous, there is no room for this Court to apply rules of interpretation.”
Taylor v. Est. of Taylor, 719 P.2d 234 (Wyo. 1986). “A cause of action for fraud does not accrue until the fraud is discovered, § 1-3-106, W.S.1977. Furthermore the cause of action for fraud does survive the death of the individual accused of fraud, § 1-4-101, W.”
Corkill v. Knowles, 955 P.2d 438 (Wyo. 1998). “A claim against a professional must be brought after the discovery of the alleged act, error or omission.”
Young v. Young, 709 P.2d 1254 (Wyo. 1985). “W.S. 1-3-106 provides in pertinent part: “A cause of action for the wrongful taking of personal property is not deemed to have accrued until the wrongdoer is discovered.”
Richardson Assocs. v. Lincoln-Devore, Inc., 806 P.2d 790 (Wyo. 1991). “1985); W.S. 1-3-106, conversion and fraud premised on discovery; and W.”
Peggy Rose Revocable Trust v. Eppich, 640 N.W.2d 601 (Minn. 2002). “Code Ann. § 15-3-530(7) (Law. Co-op.1977 & Supp.”
Redland v. Redland, 346 P.3d 857 (Wyo. 2015). “1985); W.S. 1-3-106, conversion and fraud premised on discovery; and W.”
Robert L. Kroenlein Trust By & Through Deborah Alden, Successor Tr., & Chugwater Brewing Co., Inc., a Wyoming Corp. v. Gary Bruce Kirchhefer, Commodore Bar, Inc., Rick L. Bowen, Silver Dollar Bar of Lusk, Llc., & Larry H. Halligan, 2015 WY 127 (Wyo. 2015). “In so arguing, Plaintiffs point to the language of Wyo. Stat. Ann. § 1-3-106 , which provides: A cause of action for the wrongful taking of personal property is not deemed to have accrued until the wrongdoer is discovered.”
Marian I. Erdelyi v. Bradley T. Lott, 2014 WY 48 (Wyo. 2014). “Wyo. Stat. Ann. § 1-3-106 (LexisNexis 2013).”
Henry v. Pro 10 Originals, LLC, 698 F. Supp. 2d 1279 (D. Wyo. 2010). “Wyo. Stat. § 1-3-106 provides that a cause of action on the ground of fraud is not deemed to have accrued until the discovery of the fraud.”
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