Wyoming Contract Law in Action: Robinson v. Black and the Power of Unjust Enrichment

In Wyoming, not every agreement is written in ink. Sometimes, services are rendered without formal contracts — but that doesn't mean the law offers no remedy. The Wyoming Supreme Court’s recent decision in Robinson v. Black reminds us that even without a signed contract, courts can recognize when one party is unjustly enriched at another’s expense. 

The Background: Work Done, But No Check in Hand 

In Robinson v. Black, a rancher (Mr. Black) sued a former day laborer (Ms. Winfield) for breach of contract over an unpaid loan. She and her boyfriend, Samuel Robinson, counterclaimed, asserting that they performed extensive labor, hot-shot trucking, and livestock boarding for Mr. Black without being paid — even though he benefitted from the work. 

Despite the absence of a signed contract, the Wyoming Supreme Court held that the laborers were entitled to payment under unjust enrichment, awarding them nearly $23,000 in damages. 

Elements of a Valid Contract (and What Was Missing Here) 

To establish a contract in Wyoming, five elements must generally be present: 

1. Offer – A clear proposal to do something. 

2. Acceptance – Agreement to the terms. 

3. Consideration – Each side provides something of value. 

4. Mutual assent – A meeting of the minds. 

5. Legality – The agreement must not violate law or public policy. 

In Robinson, the parties never formed a formal agreement. There was no written contract or clear verbal agreement on compensation — so the workers turned to a different legal doctrine: unjust enrichment. 

Unjust Enrichment: When Equity Demands Compensation 

Wyoming courts recognize unjust enrichment as an equitable doctrine used to prevent one party from unfairly benefiting at another’s expense. To prove unjust enrichment, a plaintiff must show: 

1. Valuable services or materials were provided, 

2. To the defendant, 

3. Which the defendant accepted and benefited from, 

4. Under circumstances where the plaintiff reasonably expected to be paid, and the defendant would be unjustly enriched without compensation. 

The Supreme Court emphasized that actual notice of the expectation to be paid isn't required — only that the circumstances reasonably notified the defendant of that expectation. In this case, the workers spent months building fences, hauling supplies, feeding livestock, and incurring costs, all while using their own equipment. They had prior payment history with Mr. Black and even presented him with a bill. The court concluded that “Mr. Black could not have reasonably believed that Ms. Winfield and Mr. Robinson were volunteering 90 days of work.” 

Additional Doctrines at Play: Discovery Violations and Mitigation of Damages 

The Court also addressed two other contract-adjacent doctrines: 

• Discovery Violations: Mr. Black used trial evidence (a ranch diary) that had not been disclosed earlier, but the court found this was a harmless error because it didn’t affect the outcome and was ultimately used by both sides. 

• Mitigation of Damages: The Court reduced some of the damages related to boarding livestock because the plaintiffs failed to return the animals after demand, violating their duty to minimize losses. 

Practical Takeaways for Wyoming Residents and Businesses 

1. Always clarify payment expectations – If you’re performing work, make your expectation of payment known — and in writing if possible. 

2. Keep records – Even in informal arrangements, maintain logs, invoices, and communications. They can make or break a claim. 

3. Equity can fill the gaps – Courts will not allow one party to be unfairly enriched, even if a formal contract doesn't exist. 

4. Don’t ignore procedural duties – If you go to court, follow all discovery rules and mitigate your damages where possible. 

Need Help with a Contract or Dispute? 

Whether you're drafting a complex agreement or dealing with the fallout from an informal deal gone wrong, Attorney John D. Bowers is here to help. With over 28 years of experience in Wyoming and surrounding states — and recognition as a Super Lawyer for the Intermountain States — John D. Bowers offers unmatched insight in contract litigation and equitable claims like unjust enrichment. 

📞 Call 307-885-1000 for a consultation.