Wyo. Stat. » Wyo. Stat. / Title 34 - Property, Conveyances and Security Transactions / Chapter 1 - GENERAL PROVISIONS / Article 1 - IN GENERAL
Wyoming Statutes

Wyo. Stat. § 34-1-120 (2026)

Unrecorded conveyance void as to subsequent

✓ current as of May 2026
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purchasers recording first.

Every conveyance of real estate within this state, hereafter
made, which shall not be recorded as required by law, shall be
void, as against any subsequent purchaser or purchasers in good
faith and for a valuable consideration of the same real estate
or any portion thereof, whose conveyance shall be first duly
recorded.
Notes of Decisions
Cited in 21 cases (3 in the last 5 years), 1981–2024 · leading case: Horse Creek Conservation Dist. v. State Ex Rel. Wyoming Attorney Gen., 2009 WY 143 (Wyo. 2009).
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Horse Creek Conservation Dist. v. State Ex Rel. Wyoming Attorney Gen., 2009 WY 143 (Wyo. 2009). · cites it 12× “It relies upon Wyo. Stat. Ann. § 34-1-120 in support of its position: Every conveyance of real estate within this state, hereafter made, which shall not be recorded as required by law, shall be void, as against any subsequent purchaser or purchasers in good faith and for a…”
Anne Holding & Crandall Creek Ranch, Co., a Wyoming Corp. v. Larry Luckinbill the Larry Lee Luckinbill Living Trust John Lennon & Melanie Lennon, 2022 WY 10 (Wyo. 2022). · cites it 9× “Relying upon the operation of Wyo. Stat. Ann. § 34-1-120 , the Bentleys brought suit alleging that the easement could not be enforced against them as bona fide purchasers.”
Grose v. Sauvageau, 942 P.2d 398 (Wyo. 1997). · cites it 16× “Despite the allegations of inappropriate conduct, appellants’ failure to acquire or record a valid deed to the property necessitates the legal recognition of the quitclaim deed filed by appellee as a subsequent good faith purchaser without notice pursuant to Wyo. Stat. §…”
Condos v. Trapp, 717 P.2d 827 (Wyo. 1986). · cites it 18× “Whether the trial Court properly applied the Wyoming Recording Statute, W.S. § 34-1-120 in determining who was the last Grantee who should bear the deficiency.”
Condos v. Trapp, 739 P.2d 749 (Wyo. 1987). · cites it 14× “Thus, in the summary judgment entered, the trial court stated: “After hearing the arguments of counsel, the Court found that W.S. § 34-1-120 applied and that the Hammonds, and thus the Lettzes and the Wilsons, were the last grantees.”
Chancy & Kim Wheeldon v. Elk Feed Grounds House, Llc, a Wyoming Ltd. Liab. Co., 2021 WY 71 (Wyo. 2021). · cites it 7× “Accordingly, they contend Elk Feed does not deserve the protections that Wyo. Stat. Ann. § 34-1-120 6 and the 6 The statute provides: “Every conveyance of real estate within this state, hereafter made, which shall not be recorded as required by law, shall be void, as against any…”
Wilkie v. Robbins, 551 U.S. 537 (2007). “See Wyo. Stat. Ann. § 34-1-120 (2005). When the Bureau's employee Joseph Vessels [1] discovered, in June 1994, that the Bureau's inaction had cost it the easement, he telephoned Robbins and demanded an easement to replace Nelson's.”
Kennedy Oil v. Lance Oil & Gas Co., 2006 WY 9 (Wyo. 2006). · cites it 4× “The Recording Act [¶ 32] Wyo. Stat. Ann. § 34-1-120 (Lex-isNexis 2005) provides as follows: Every conveyance of real estate within this state, hereafter made, which shall not be recorded as required by law, shall be void, as against any subsequent purchaser or purchasers in good…”
White v. Woods, 208 P.3d 597 (Wyo. 2009). · cites it 4× “Wyo. Stat. Ann. § 34-1-120 . When the Mileys did not *604 pay their taxes, the Whites purchased the property at the tax sale in 1974.”
Ludvik v. James S. Jackson Co., Inc., 635 P.2d 1135 (Wyo. 1981). · cites it 4× “Section 34-1-120, W.S. 1977, provides: "Every conveyance of real estate within this state, hereafter made, which shall not be recorded as required by law, shall be void, as against any subsequent purchaser or purchasers in good faith and for a valuable consideration of the same…”
Bentley v. Dir. of Off. State Lands, 2007 WY 94 (Wyo. 2007). · cites it 11× “Invoking bona fide purchaser status, they assert the easement cannot be enforced against them, relying upon the operation of Wyo. Stat. Ann. § 34-1-120 . The Bentleys' argument is premised on the nature of the State's ownership after the Sales Contract was executed.”
Robbins v. Bureau of Land Mgmt., 252 F. Supp. 2d 1286 (D. Wyo. 2003). · cites it 4× “at ¶ 21; See also Wyo. Stat. Ann. § 34-1-120 (providing that an unrecorded conveyance is void against a subsequent purchaser for value who, without notice, first records)).”
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