Thompson v. Board of County Commissioners of the County of Sublette

Summary

The Supreme Court of Wyoming affirmed a permanent injunction barring Stuart and Mary Thompson from using their agricultural-zoned property for activities associated with a log home business and ski enterprise. The court held that equitable estoppel and laches did not prevent Sublette County from enforcing its zoning regulations, and that the ski-related activities were not incidental to a principal agricultural use.

Holdings

1. The district court did not abuse its discretion in rejecting the Thompsons' equitable-estoppel defense because the county was acting in a governmental capacity, no recognized proprietary-capacity exception applied, and the Thompsons failed to establish rare and exceptional circumstances or affirmative misconduct sufficient to estop the county from enforcing its zoning regulations.
2. The district court did not abuse its discretion in rejecting the Thompsons' laches defense; laches did not bar the county from enforcing its zoning resolutions.
3. The White Pine activities on the Thompsons' property were not authorized as winter-sports uses incidental to a principal agricultural use because the property's primary use was for Logcrafters operations rather than agriculture.

Questions Presented

1. Whether the district court erred in rejecting the Thompsons' equitable-estoppel defense to the county's request for injunctive relief.
2. Whether the district court erred in rejecting the Thompsons' laches defense.
3. Whether activities associated with White Pine were authorized under the county zoning regulations as winter-sports uses incidental to a principal agricultural use in an A-1 zone.

Disposition

affirmed