Wyoming Statutes
Wyo. Stat. § 4-10-1001 (2026)
Remedies for breach of trust.
✓ current as of May 2026
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(a) A violation by a fiduciary of a duty the fiduciary
owes to a beneficiary is a breach of trust.
(b) To remedy a breach of trust that has occurred or may
occur, the court may:
(i) Compel the fiduciary to perform the fiduciary's
duties;
(ii) Enjoin the fiduciary from committing a breach of
trust;
(iii) Compel the fiduciary to redress a breach of
trust by paying money, restoring property or other means;
(iv) Order a fiduciary to account;
(v) Appoint a special fiduciary to take possession of
the trust property and administer the trust;
(vi) Suspend the fiduciary;
(vii) Remove the fiduciary as provided in W.S.
4-10-706;
(viii) Reduce or deny compensation to the fiduciary;
(ix) Subject to the rights of persons dealing with a
fiduciary as provided in W.S. 4-10-1013, void an act of the
fiduciary, impose a lien or a constructive trust on trust
property or trace trust property wrongfully disposed of and
recover the property or its proceeds; or
(x) Order any other appropriate relief.Notes of Decisions
Cited in 5
cases (3 in the last 5 years), 2019–2024 · leading case: In the Matter of the J. Kent Kinniburgh Revocable Trust Dated January 27, 1992, as Amended & Restated: Janel K. Kinniburgh, Beneficiary & Successor Tr. of the J. Kent Kinniburgh Revocable Trust Dated January 27, 1992 v. Jacque Moncur & Rosemary Steele, Successor Co-Trs. of the J. Kent Kinniburgh Revocable Trust Dated January 27, 1992, 2023 WY 56 (Wyo. 2023).
In the Matter of the J. Kent Kinniburgh Revocable Trust Dated January 27, 1992, as Amended & Restated: Janel K. Kinniburgh, Beneficiary & Successor Tr. of the J. Kent Kinniburgh Revocable Trust Dated January 27, 1992 v. Jacque Moncur & Rosemary Steele, Successor Co-Trs. of the J. Kent Kinniburgh Revocable Trust Dated January 27, 1992, 2023 WY 56 (Wyo. 2023). “Wyo. Stat. Ann. § 4-10-1001 (a) (LexisNexis 2021).”
In the Matter of the Phyllis V. Mcdill Revocable Trust: Thomas P. Mcdill, Jr., In His Individual Capacity as Beneficiary & Successor Tr. of the Phyliss Mcdill Revocable Trust. v. Michael G. Mcdill, In His Individual Capacity as Beneficiary of the Phyliss Mcdill Revocable Trust, 2022 WY 40 (Wyo. 2022). “” Wyo. Stat. Ann. § 4-10-1001 (a) (LexisNexis 2021) (emphasis added).”
Redland v. Redland (In re Robert & Irene Redland Fam. Trust, Dated August 10, 1989), 435 P.3d 349 (Wyo. 2019). “§ 4-10-1001 (a), (b)(vii), and in the following circumstances: (i) The trustee has committed a serious breach of trust; (ii) Lack of cooperation among cotrustees substantially impairs the administration of the trust; (iii) Because of unfitness, unwillingness or persistent…”
In the Matter of the Phyllis V. Mcdill Revocable Trust: Thomas P. Mcdill, Jr. v. Michael G. Mcdill, 2020 WY 99 (Wyo. 2020). “He later filed an Amended Response, also pro se, asking that Michael be removed as Trustee for (1) failing to provide an accounting under § 4-10- 813; (2) thwarting Thomas’s efforts to obtain such an accounting under Wyo. Stat. Ann. § 4-10-1001 (v-viii) (LexisNexis 2019); (3)…”
David Spurlock v. Wyoming Trust Co., 2024 WY 19 (Wyo. 2024). “eal estate transaction; to enjoin the Trustee from committing further breaches of trust; to compel the Trustees to redress their breaches of trust by paying money or restoring property; to order the Trustee to provide an accounting; suspend the Trustee from taking further action…”
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