Law & Justice

Wyoming Supreme Court Grants Private Road for 640‑acre Parcel, Upholds $61,200 Compensation

By TOI World Desk

A 640‑acre parcel in northern Albany County, Wyoming, owned by Wagonhound Land & Livestock Company, was surrounded almost entirely by Little Medicine Creek Ranch (formerly Burnett Ranch). In April 2023, Wagonhound requested a legally enforceable right‑of‑way to the isolated property, proposing a 30‑foot‑wide corridor along existing ranch roads. Negotiations failed, and Wagonhound filed a petition under Wyoming’s private road statute to create a private road across the ranch’s land. Little Medicine Creek Ranch opposed the request, arguing that Wagonhound could use an existing two‑track route across Bureau of Land Management (BLM) land and a proposed Parsons Creek Route on public land. The Supreme Court found that neither route provided legally enforceable vehicle access to a public road, as the rough track crossed state trust land and was effectively controlled by the ranch, and the Parsons Creek Route did not physically exist. The court therefore affirmed that a private road was necessary.

The district court had appointed independent viewers and appraisers who recommended Wagonhound’s proposed route because it was shorter, more direct, and more practical than the ranch’s alternative, which would have required construction across a rocky ridge and could have made winter access difficult. The viewers estimated that the private road would affect 680 acres of the ranch and calculated a $90‑per‑acre reduction in value, resulting in a $61,200 compensation award. Little Medicine Creek Ranch challenged the calculation, citing potential operational losses such as dust‑related livestock health problems, additional staffing costs, and reduced hunting opportunities. The Supreme Court upheld the award, noting that Wyoming’s private road statute requires a before‑and‑after appraisal to determine the reduction in property value but does not provide compensation for indirect future business losses. The ranch had not presented evidence disputing the affected acreage or the $90‑per‑acre reduction.

The court also overturned two conditions imposed by the district court. First, it removed a requirement that Wagonhound pay for any damage to the road regardless of who caused it; Wagonhound remains responsible for maintaining the road for its own use but is not automatically liable for damage caused by others. Second, it lifted a restriction that prohibited vehicles with more than four axles, including semi‑trailers, from using the road, finding insufficient evidence that heavy vehicles would create unreasonable disturbances. The court upheld the requirement that Wagonhound regularly apply water to suppress dust, citing its potential impact on livestock. It also rejected the ranch’s request to limit the road exclusively to agricultural use.

On September 23, 2026, the Wyoming Supreme Court affirmed the necessity of the private road, the compensation award, and the good‑faith basis of the route selection, while reversing the two road conditions. The decision allows Wagonhound to obtain legally enforceable vehicle access to its 640‑acre property and requires it to pay Little Medicine Creek Ranch $61,200, while clarifying that a rough track across public land does not constitute a legally usable connection to a public road when no enforceable access exists.