Pedro/Aspen, Ltd. v. Board of County Commissioners for Natrona County

Summary

The Wyoming Supreme Court held that Pedro/Aspen had standing to challenge Natrona County's major land subdivision regulation because its contract-for-deed interest and parcel sales constituted a sufficient tangible interest. The court further held that the county lacked statutory authority to require approval for subdivisions involving parcels larger than thirty-five acres, reversed the district court's judgment, and rejected the county's reliance on its authority to enact more restrictive subdivision requirements.

Holdings

1. Pedro/Aspen had standing because its equitable interest under the contract for deed and its active sales of approximately forty-acre parcels constituted a sufficient tangible interest directly affected by the regulation.
2. Natrona County lacked statutory authority to require county approval for subdivision of land into parcels larger than thirty-five acres; Chapter IX therefore exceeded the county's statutory authority and was invalid to that extent.

Questions Presented

1. Whether Pedro/Aspen had standing under the Uniform Declaratory Judgments Act to challenge Chapter IX of the Natrona County Zoning Resolution.
2. Whether Natrona County had statutory authority to require approval for the subdivision of land into parcels larger than thirty-five acres.

Disposition

reversed_and_remanded