Wyoming Statutes

Wyo. Stat. § 34-12-104 (2026)

Townsites; effect of acknowledgment and

✓ current as of May 2026
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recording.

The acknowledgment and recording of such plat, is equivalent to
a deed in fee simple of such portion of the premises platted as
is on such plat set apart for streets, or other public use, or
is thereon dedicated to charitable, religious or educational
purposes.
Notes of Decisions
Cited in 7 cases, 1983–2007 · leading case: City of Evanston v. Robinson, 702 P.2d 1283 (Wyo. 1985).
City of Evanston v. Robinson, 702 P.2d 1283 (Wyo. 1985). · cites it 26× “Section 34-12-104, W.S. 1977, of the Act has remained substantially the same since its adoption and provides: "The acknowledgment and recording of such plat, is equivalent to a deed in fee simple of such portion of the premises platted as is on such plat set apart for streets,…”
Ruby Drilling Co., Inc. v. Billingsly, 660 P.2d 377 (Wyo. 1983). · cites it 12× “The appellant argues that it is of no significance that the notation on the plat does not state that the roadway easements are dedicated to the public because the language of § 34-12-104, W.S. 1977, [3] requires a finding that the recording of the plat operates as a dedication…”
Owsley v. Robinson, 2003 WY 33 (Wyo. 2003). · cites it 7× “The district court specifically ruled that, pursuant to Wyo. Stat. Ann. § 34-12-104 (LexisNexis 2001), the recording of a plat is the equivalent of granting the public a fee simple interest in the portions set aside for streets or other public use.”
Sare v. Sheridan Cnty. Bd. of Cnty. Commissioners, 784 P.2d 593 (Wyo. 1989). · cites it 10× “NOTES [1] Wyo. Stat. § 34-12-104 (1977) provides: The acknowledgment and recording of such plat, is equivalent to a deed in fee simple of such portion of the premises platted as is on such plat set apart for streets, or other public use, or is thereon dedicated to charitable,…”
Town of Moorcroft v. Lang, 761 P.2d 96 (Wyo. 1988). · cites it 8× “In that case, we held that a statutory dedication conveyed a determinable fee in the surface estate to the city. The holding was compatible with the rationale of our prior decisions, as well as with the reasoning of courts in other jurisdictions that have adopted language in…”
Town of Moorcroft v. Lang, 779 P.2d 1180 (Wyo. 1989). · cites it 4× “W.S. 34-12-104, supra. This result occurs if no abutting lots are sold.”
Sunshine Custom Paints & Body, Inc. v. South Douglas High. Water & Sewer Dist., 2007 WY 206 (Wyo. 2007). · cites it 2× “§ 34-12-104 (LexisNexis 2007) articulates the effect of recording a plat: The acknowledgment and recording of such plat, is equivalent to a deed in fee simple of such portion of the premises platted as is on such plat set apart for streets, or other public use, or is thereon…”
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