Leeks Canyon Ranch, LLC, a Wyoming limited liability company; Leeks Canyon, LLC, a Wyoming limited liability company; Elizabeth Lockhart and Kelly Lockhart, wife and husband v. Callahan River Ranch, LLC, a Wyoming limited liability company; and Porter River Ranch, LLC, a Wyoming limited liability company

Summary

The Wyoming Supreme Court reviewed a dispute over whether deed language created a valid easement across ranch parcels in Teton County. The court held that the 1992 conveyances reserved an easement benefiting Parcel 19 and that the easement description was sufficiently specific under Wyo. Stat. Ann. § 34-1-141. The court reversed the district court’s determination that the express easement was invalid and remanded for entry of an order consistent with its opinion.

Holdings

1. The 1992 deeds reserved an easement over Parcels 20, 24, and 27 for the benefit of Parcel 19. No particular words are required to reserve an easement; the deed language and surrounding circumstances demonstrated the Trust's intent.
2. The easement description was sufficiently specific to locate the easement and therefore was not subject to the statute's one-year supplemental-recording requirement.
3. The 1992 reserved easement was appurtenant to Parcel 19, not in gross, and therefore passed to subsequent owners, including the Lockharts.
4. The 1998 deed conveyed to Elizabeth Lockhart a nonexclusive sixty-foot road and utility easement across Parcel 25 to Shootin' Iron County Road 22-20.

Questions Presented

1. Whether the 1992 conveyances reserved an easement benefiting Parcel 19.
2. Whether the easement description was sufficiently specific to locate the easement under Wyo. Stat. Ann. § 34-1-141.
3. Whether the reserved easement was appurtenant to Parcel 19 or in gross.
4. Whether the 1998 conveyance of Parcel 19 conveyed an easement across Parcel 25.

Disposition

reversed_and_remanded