Wyoming lawAdverse PossessionQuiet TitlePublic Lands

Adverse Possession in Wyoming

September 24, 2026 · LawDiver Research Team

Looking for adverse possession in Wyoming or squatters rights in Wyoming? Wyoming law answers those questions with a limitations / prescription statute — primarily Wyo. Stat. § 1-3-103 — not a single nationwide rule. This guide explains the Wyoming period (10 years), the classic elements as Wyoming courts frame them, color of title and tax conditions, how to quiet title, and how recent anti-squatting reforms (if any) interact with mature claims.

Key takeaways

  • Statutory period in Wyoming: 10 years.
  • Primary authority: Wyo. Stat. § 1-3-103.
  • Taxes: No — Wyoming does not require tax payment as an element of adverse possession.
  • Color of title: No shorter color-of-title track.
  • Quiet-title / AP forum: District court quiet-title actions in the county where the real property is located.
  • Pair this page with the LawDiver search rail scoped to Wyoming for live opinions on hostile possession, tacking, and boundary disputes.

Current adverse possession law in Wyoming

Wyoming’s adverse-possession period is ten years under Wyo. Stat. § 1-3-103. There is no shorter color-of-title statute and no tax element. Claimants must prove classic adverse-possession elements. Quiet-title actions proceed in district court. Federal and state public lands cannot be acquired by adverse possession.

Statutory period

Period: 10 years

Under Wyo. Stat. § 1-3-103, the clock generally runs only while possession is adverse and continuous. Permission from the true owner, abandonment, or ouster can stop or reset the period. Always read the full statute text and any disability / tolling provisions before relying on a secondary summary.

Elements Wyoming courts require

Wyoming requires actual, open, notorious, exclusive, continuous, and hostile possession under claim of right for ten years under Wyo. Stat. § 1-3-103.

In plain terms, adverse possession is not “camping for a few weeks.” Courts look for possession that looks like ownership — fencing, cultivation, building, exclusive control — maintained for the full period without the owner’s permission.

Hostility and claim of right

Wyoming hostility is objective claim-of-right; permission defeats adversity. Good faith is not generally required.

Permission is the classic defense. A neighbor who uses a strip of land with the owner’s consent is usually a permissive user, not an adverse possessor — until a clear repudiation of the permission starts the adverse clock.

Color of title

No shorter color-of-title track.

Color of title is a document that looks like a conveyance (deed, judgment, or instrument) but is defective. It often expands the geographic footprint of constructive possession and, in some states, shortens the years required.

Property taxes

No — Wyoming does not require tax payment as an element of adverse possession.

Where taxes are required, courts often demand certified collector records for the full period. Paying taxes alone rarely creates title without the possession elements.

Tacking successive possessions

Tacking is permitted with privity.

Without privity, successive squatters cannot stitch their years together. With privity (deed, inheritance, or transfer of the possessory interest), tacking can complete a period no single occupant finished alone.

Government and public land

Adverse possession does not run against the United States or the State of Wyoming; extensive federal public lands in Wyoming are off-limits.

How to quiet title or defend against a claim

Adverse possession usually becomes marketable title only after a court decree. In Wyoming, actions are typically filed in District court quiet-title actions in the county where the real property is located. Claimants plead the elements and period under Wyo. Stat. § 1-3-103; owners defend with permission, interruption, lack of exclusivity, survey / boundary evidence, or government-land immunity.

Practical sequence for a claimant:

  1. Confirm the correct statutory track (color of title, taxes, acreage caps).
  2. Assemble possession evidence (photos, surveys, tax receipts, witness affidavits).
  3. File quiet title / declaratory judgment in the proper Wyoming forum.
  4. Serve all record owners and lienholders; expect a boundary or survey fight.
  5. Record the judgment so the title plant and future buyers see the decree.

Practical sequence for an owner who discovers an encroachment:

  1. Document the intrusion immediately (survey, photos, written objection).
  2. Send a clear written revocation of any implied permission.
  3. Consider ejectment / unlawful detainer before the statutory period runs.
  4. Do not use self-help lockouts if the occupant claims residency — use court or statutory sheriff process.

Removing unauthorized occupants

Wyoming has no widely reported statewide sheriff-complaint “anti-squatting” fast track comparable to the 2024 Florida / Georgia wave. Owners typically use ejectment, unlawful detainer / forcible entry, or quiet-title practice — not self-help lockouts or utility shutoffs.

Case law: how Wyoming courts decide adverse possession

The opinions below are in the LawDiver corpus, with block quotes pulled from the opinion text so you can jump into the full decisions.

Little Medicine Creek Ranch, Inc., a Wyoming Corporation, F/K/A Burnett Ranch, Inc. v. Serge M. d'Elia and Lilian

Little Medicine Creek Ranch, Inc., a Wyoming Corporation, F/K/A Burnett Ranch, Inc. v. Serge M. d'Elia and Lilian, 2023 WY 30 (2023)

…volume. FENN, Justice. [¶1] This is the second appeal of an adverse possession case involving two neighboring cattle ranches—the Burnett Ranch and the Warbonnet Ranch.2 The Appellant, Little Medicine Creek Ranch, Inc., f/k/a Burnett Ranch, Inc., owns a ranch in Albany County that has historically been known as the Burnett Ranch. The Burnett Ranch is enclosed by a perimeter fenc…

Open the full opinion on LawDiver to read how Wyoming courts apply adverse-possession elements in context.

Howard L. WHITE and Joslyn R. White, (Plaintiffs) v. Heath S. WHEELER and Tanya D. Wheeler, (Defendants)

Howard L. WHITE and Joslyn R. White, (Plaintiffs) v. Heath S. WHEELER and Tanya D. Wheeler, (Defendants), 406 P.3d 1241 (2017)

…iled a complaint against the Wheelers asserting a claim for adverse possession based on the Whites’ fencing and grazing of livestock on an approximately eight-acre strip of the Wheeler property. On cross-motions for summary judgment, the district court entered summary judgment in favor of the Wheelers, and the Whites appeal. Because genuine issues of material fact precluded sum…

Open the full opinion on LawDiver to read how Wyoming courts apply adverse-possession elements in context.

Fran GILLETT, Appellant (Defendant), v. Michael WHITE and Pamela White, Appellees (Plaintiffs)

Fran GILLETT, Appellant (Defendant), v. Michael WHITE and Pamela White, Appellees (Plaintiffs), 153 P.3d 911 (2007)

…ve title to a strip of land quieted in them on the basis of adverse possession. Ms. Gillett claims summary judgment was improper because a genuine issue of material fact existed as to whether the fence separating the strip of land from her property was a fence of convenience; the requisite ten year period for adverse possession was not met; and adverse possession can be used on…

Open the full opinion on LawDiver to read how Wyoming courts apply adverse-possession elements in context.

Practical research tips

  • Read the live text of Wyo. Stat. § 1-3-103 on LawDiver before relying on this summary.
  • Search Wyoming opinions for adverse possession Wyoming, squatters rights Wyoming, Wyo. Stat. 1-3-103, Wyoming quiet title, Wyoming claim of right, ten year adverse possession Wyoming.
  • Cross-check survey descriptions, tax parcels, and recorded instruments — many AP fights are boundary cases in disguise.
  • Distinguish short-term squatting (removal / trespass) from multi-year adverse possession (quiet title).

Frequently asked questions

What is the adverse possession period in Wyoming?

10 years, under Wyo. Stat. § 1-3-103. Shorter tracks may apply with color of title or tax payment where the statute so provides.

Do squatters have rights in Wyoming?

“Squatters rights” is popular language for adverse possession. Wyoming recognizes the doctrine, but only after the statutory elements and period are met — and usually only after a quiet-title judgment. Short-term unauthorized occupation is typically trespass / eviction territory, not title.

Are property taxes required for adverse possession in Wyoming?

No — Wyoming does not require tax payment as an element of adverse possession.

What is color of title in Wyoming?

No shorter color-of-title track.

Can you adversely possess government land in Wyoming?

Adverse possession does not run against the United States or the State of Wyoming; extensive federal public lands in Wyoming are off-limits.

How do I quiet title after adverse possession in Wyoming?

File in District court quiet-title actions in the county where the real property is located, plead the elements under Wyo. Stat. § 1-3-103, serve interested parties, and record any judgment. Use LawDiver to pull recent Wyoming quiet-title and adverse-possession opinions before drafting.

Disclaimer

This guide is general legal information about adverse possession in Wyoming, not legal advice. Statutes and case law change. Confirm the current text of Wyo. Stat. § 1-3-103 and consult a licensed Wyoming real-estate attorney about your parcel before filing or relying on a possession claim.

Adverse Possession in Wyoming (2026) | LawDiver