Wyoming Statutes
Wyo. Stat. § 33-28-115 (2026)
Unlicensed person may not maintain action for
✓ current as of May 2026
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fee. No action or suit shall be instituted, nor recovery be had, in any court of this state by any person for compensation for any real estate activity unless the person was licensed by the commission under this act at the time of engaging in real estate activity.
Notes of Decisions
Cited in 4
cases, 1983–2005 · leading case: Richardson v. Schaub, 796 P.2d 1304 (Wyo. 1990).
Richardson v. Schaub, 796 P.2d 1304 (Wyo. 1990). “" [3] The ruling of the trial court was premised upon § 33-28-115, W.S. 1977, which states: "No action or suit shall be instituted, nor recovery be had, in any court of this state by any person for compensation for any act done or service rendered, which is prohibited under this…”
Battlefield, Inc. v. Neely, 656 P.2d 1154 (Wyo. 1983). “The next step in sequence is the invocation of § 33-28-115, W.S. 1977, which provides as follows: "No person shall maintain an action in any court of this state for the recovery of a commission, fee, or compensation for *1166 any act done, the doing of which is prohibited under…”
Simek v. J.P. King Auction Co., 160 F. App'x 675 (10th Cir. 2005). “While the Real Estate License Act states that an unlicensed broker may not bring suit to recover a commission, Wyo. Stat. Ann. § 33-28-115 , the Wyoming Supreme Court has observed that generally, in the absence of some further violation, “one who has paid money to an unlicensed…”
Battlefield, Inc. v. Neely, 656 P.2d 1150 (Wyo. 1983). “The next step in sequence is the invocation of § 33-28-115, W.S.1977, which provides as follows: “No person shall maintain an action in any court of this state for the recovery of a commission, fee, or compensation for *1162 any act done, the doing of which is prohibited under…”
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