Sonnett v. First American Title Insurance Company
Wyoming Supreme Court
309 P.3d 799 (2013)
- Written by Robert Cane, JD
Facts
The Sonnetts (plaintiffs) purchased a large parcel of property with the intention of developing it further. The Sonnetts also purchased a title-insurance policy from First American Title Insurance Company (First American) (defendant). Unknown to the Sonnetts at the time of purchase, earlier owners of the property had proposed a master plan and corresponding amendments to the local zoning ordinances, which the Sublette County Planning and Zoning Commission (the commission) had adopted via zoning resolution in 1970 (1970 zoning resolution). Notably, the Sonnetts’ title-insurance policy expressly excluded coverage for the 1970 zoning resolution. Further, the policy had a standard provision that excluded loss or damage due to governmental regulations. The Sonnetts filed a claim with First American, which First American denied. Then, the Sonnetts sued First American, arguing that the master plan was a set of restrictive covenants. The lower court granted summary judgment in favor of First American. The Sonnetts appealed.
Rule of Law
Issue
Holding and Reasoning (Voigt, J.)
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