John B. Harber and Sylvia Harber, Trustees Under the Harber Family Trust, Dated April 1, 1997; and Larry Lozier And…

Summary

The Wyoming Supreme Court reversed a district court judgment finding that the Jensens had acquired an irrevocable license to use a road crossing the Harbers' and Loziers' property for ranch access. The court held that an irrevocable license requires proof that the licensor had knowledge of the licensee's improvements and took affirmative action to induce the licensee's reliance, and that the improvements themselves must require use of the licensor's property. Because the Jensens never notified the landowners of their intent to make improvements, never requested permission, and their ranch had alternate (albeit expensive) access, the elements of an irrevocable license were not satisfied. The court remanded with directions to enter orders consistent with its opinion.