Gray v. Stratton Real Estate

Summary

The Wyoming Supreme Court affirmed a judgment requiring Gray to pay Stratton Real Estate a $10,000 commission under an exclusive leasing and commission agreement. The court held that Wyo. Stat. § 33-28-111(a)(xx), which regulates listing agreements for the sale of property, does not apply to lease agreements and does not render the contract unenforceable for lacking a definite expiration date. The court also determined that the appeal lacked a reasonable legal basis and awarded sanctions, subject to submission of costs and attorney fees.

Holdings

1. Section 33-28-111(a)(xx) is a licensing regulatory provision that applies to listing agreements for the sale of real property, not to agreements concerning the negotiation of a lease.
2. The absence of a definite expiration date did not make the written leasing commission agreement unenforceable, void, or contrary to public policy.
3. Sanctions were appropriate because the appeal lacked cogent argument, pertinent authority, and a good-faith legal basis.

Questions Presented

1. Whether Wyo. Stat. Ann. § 33-28-111(a)(xx), which requires certain real estate listing agreements to contain a definite expiration date, applies to an agreement for negotiating a lease.
2. Whether the absence of a definite expiration date rendered the written commission agreement unenforceable or void as against public policy.
3. Whether sanctions should be imposed for an appeal lacking a reasonable legal basis.

Disposition

affirmed