Wyoming Statutes

Wyo. Stat. § 34.1-2-201 (2026)

Formal requirements; statute of frauds.

✓ current as of May 2026
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     (a) Except as otherwise provided in this section a
contract for the sale of goods for the price of five hundred
dollars ($500.00) or more is not enforceable by way of action or
defense unless there is some writing sufficient to indicate that
a contract for sale has been made between the parties and signed
by the party against whom enforcement is sought or by his
authorized agent or broker. A writing is not insufficient
because it omits or incorrectly states a term agreed upon but
the contract is not enforceable under this paragraph beyond the
quantity of goods shown in such writing.

     (b) Between merchants if within a reasonable time a
writing in confirmation of the contract and sufficient against
the sender is received and the party receiving it has reason to
know its contents, it satisfies the requirements of subsection
(a) against such party unless written notice of objection to its
contents is given within ten (10) days after it is received.

     (c) A contract which does not satisfy the requirements of
subsection (a) but which is valid in other respects is
enforceable:

          (i) If the goods are to be specially manufactured for
the buyer and are not suitable for sale to others in the
ordinary course of the seller's business and the seller, before
notice of repudiation is received and under circumstances which
reasonably indicate that the goods are for the buyer, has made
either a substantial beginning of their manufacture or
commitments for their procurement; or

          (ii) If the party against whom enforcement is sought
admits in his pleading, testimony or otherwise in court that a
contract for sale was made, but the contract is not enforceable
under this provision beyond the quantity of goods admitted; or

          (iii) With respect to goods for which payment has
been made and accepted or which have been received and accepted
(section 34.1-2-606).
Notes of Decisions
Cited in 8 cases (1 in the last 5 years), 1992–2024 · leading case: B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809 (Wyo. 1992).
B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809 (Wyo. 1992). · cites it 12× “In the Certification of Question of State Law, that court states the certified question to be: Under the law of the State of Wyoming, may an oral promise otherwise within the statute of frauds as pronounced in Wyo. Stat. § 34.1-2-201 [1991] and the Uniform Commercial Code,…”
Paul Sorum v. Mike Sikorski, 2024 WY 124 (Wyo. 2024). · cites it 7× “Sorum came to arguing the statute of frauds in his brief is the reference to Wyo. Stat. Ann. § 34.1-2-201 . Wyo. Stat.”
Metz Beverage Co. v. Wyoming Beverages, Inc., 2002 WY 21 (Wyo. 2002). · cites it 2× “[¶183] The statute of frauds relating to the Uniform Commercial Code is found at *1056 Wyo. Stat. Ann. § 34.1-2-201 (LexisNexis 2001), which provides as follows: (a) Exeept as otherwise provided in this section a contract for the sale of goods for the price of five hundred…”
Cargill, Inc. v. Mountain Cement Co., 891 P.2d 57 (Wyo. 1995). · cites it 4× “Wyo. Stat. § 34.1-2-201 (1991). This argument lacks merit because the transaction falls within the scope of a statutory exception.”
Jackman Constr., Inc., a Wyoming Corp. v. Rock Springs Winnelson Co., Inc., 2016 WY 118 (Wyo. 2016). · cites it 4× “See Wyo. Stat. Ann. § 34.1-2-201 (LexisNexis 2015).”
Roussalis v. Wyoming Med. Ctr., Inc., 4 P.3d 209 (Wyo. 2000). · cites it 2× “We said this Court "has accepted a role of leadership in invoking equitable principles to avoid injustice." Id. at 818. After touching on our precedent in this regard and quoting Restatement (Second) of Contracts § 189 (1981), we noted our approval of the use of promissory…”
Giacchino v. Est. of Stalkup, 908 P.2d 983 (Wyo. 1995). · cites it 2× “The statute of frauds found in the UCC under the article relating to sales, Wyo.Stat. § 34.1-2-201, leads to the same conclusion.”
McCarthy v. James E. Simon Co., 923 P.2d 747 (Wyo. 1996). “McCarthy also raises an argument under W.S. 34.1-2-201(a), the UCC statute of frauds.”
— Wyo. Stat. § 34.1-2-201(a) — 2 cases
B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809 (Wyo. 1992). “In the Certification of Question of State Law, that court states the certified question to be: Under the law of the State of Wyoming, may an oral promise otherwise within the statute of frauds as pronounced in Wyo. Stat. § 34.1-2-201 [1991] and the Uniform Commercial Code,…”
McCarthy v. James E. Simon Co., 923 P.2d 747 (Wyo. 1996). “McCarthy also raises an argument under W.S. 34.1-2-201(a), the UCC statute of frauds.”
— Wyo. Stat. § 34.1-2-201(c)(iii) — 1 case
B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809 (Wyo. 1992). “In the Certification of Question of State Law, that court states the certified question to be: Under the law of the State of Wyoming, may an oral promise otherwise within the statute of frauds as pronounced in Wyo. Stat. § 34.1-2-201 [1991] and the Uniform Commercial Code,…”
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