Estate Law in Wyoming: Lessons from Spurlock v. Wyoming Trust Company

Estate planning isn’t just about drafting documents — it’s about ensuring your intentions are honored and your assets are protected. The recent Wyoming Supreme Court decision in Spurlock v. Wyoming Trust Company offers a clear lesson for trustees, beneficiaries, and estate planners on the importance of interpreting trust terms, enforcing fiduciary duties, and understanding the limits of no-contest clauses. 

The Dispute: When a Beneficiary Challenges the Trustee 

David Spurlock, a beneficiary of his father’s revocable trust, sued the Wyoming Trust Company alleging mismanagement and failure to maintain trust property. After discovering significant water damage to property he purchased under the trust, David sought to remove the trustee and obtain damages for breaches of fiduciary duty. 

The trustee responded by invoking the trust's no-contest clause, arguing that David’s lawsuit triggered disinheritance. The district court agreed — but the Wyoming Supreme Court reversed. 

Key Legal Doctrines Explained 

1. Trust Interpretation: Settlor Intent is Supreme 

In Wyoming, interpreting a trust requires the court to look at the settlor’s intent, derived from the “plain language within the four corners of the document.” In Spurlock, the Court held that while the settlor wanted to avoid litigation, the trust did not prohibit all legal action. In fact, it allowed beneficiaries to seek judicial intervention in certain cases — including trustee removal. 

Lesson: Trusts should be written with clarity and foresight. But even well-drafted trusts are subject to judicial interpretation to avoid unjust or unintended outcomes. 

2. No-Contest Clauses: Enforceable, But Limited 

No-contest clauses are valid in Wyoming and can disinherit a beneficiary who improperly challenges a trust. However, courts will strictly interpret these clauses and will not apply them beyond what they clearly prohibit. 

In Spurlock, the Court emphasized: 

“A trustee cannot hide behind a no-contest clause and commit breaches of fiduciary duty with impunity.” 

Because David’s lawsuit aimed to enforce — not undermine — the trust, it did not trigger the no-contest clause. 

Lesson: Beneficiaries can hold trustees accountable without risking disinheritance — as long as the lawsuit doesn’t attempt to alter the trust itself. 

3. Fiduciary Duty: Trustees Must Act with Loyalty and Care 

A key issue in the case was whether the trustee violated fiduciary duties by failing to maintain property and provide accountings. Wyoming law imposes a fiduciary duty of loyalty, care, and full disclosure on trustees. Breaches may justify removal under Wyo. Stat. § 4-10-1001, which authorizes courts to remove trustees for cause. 

Lesson: Trustees must act in good faith and in the best interests of beneficiaries. Failure to do so can lead to personal liability and court-ordered removal. 

4. Procedural Law: Summary Judgment and Venue Rules 

The case also addressed procedural issues — including default judgments, motions to dismiss for venue, and the interpretation of “may” versus “shall” in trust clauses. The Court reiterated that permissive language (e.g., “may remove the trustee”) does not eliminate statutory rights to seek court relief. 

 Lesson: Legal strategy and careful pleading matter — both for enforcing and defending trust rights. 

Final Takeaways for Trustees and Beneficiaries in Wyoming 

• Trusts must be read as a whole — avoid interpretations that nullify express provisions. 

• Litigation to enforce fiduciary duties is not the same as a challenge to the trust itself. 

• Trustees cannot use trust language to avoid accountability. 

• Beneficiaries should document concerns and seek legal counsel before pursuing claims.