PC: AI Generated
The dispute began with a 500-acre Wyoming ranch between the Snake River and Grand Teton National Park. A Wyoming landowner’s attempt to build a second residential structure on conservation land led to years of litigation with The Nature Conservancy (TNC). Gary Binning wanted to build a guest house on property subject to a conservation easement, which restricted construction to one single-family residential structure per parcel. A conservation easement was established on the land to protect its natural, scenic, or open-space values. The easement allowed an owner to construct one additional single-family residential structure on each subdivided parcel, alongside associated improvements. It ruled that associated improvements did not include another residential structure, such as a guest house or caretaker’s quarters.
In an earlier case, the Wyoming Supreme Court interpreted that wording as permitting only one building in which one family could live.
A kitchenless design failed to resolve the Wyoming building dispute
Binning testified that Mortimer wanted to resolve the dispute and said he could build a structure if he did not call it a guest house, left out a kitchen, and followed Teton County’s Land Development Regulations. In her letter after the lunch, Mortimer said TNC would not object to a design if Teton County approved it as one single-family residential structure rather than multiple accessory residential units. He later asked his architects to design a “kitchenless wellness centre” where guests could stay overnight.
After the Wyoming Supreme Court ruling, Binning continued seeking a way to accommodate overnight visitors. He and his wife, Marianna, later met TNC’s Wyoming state director, Hayley Mortimer, for lunch in Jackson. Binning sought changes to the letter but did not refer to the alleged lunchtime promise in his response.
The court rejected Binning’s appeal, finding that the alleged promise was not sufficiently clear and that relying on it was unreasonable, according to the US Court of Appeals for the Tenth Circuit dated 15 April 2026.
After losing an earlier case before the Wyoming Supreme Court, Binning said TNC’s state director had orally agreed he could build a structure for overnight guests if it was not called a guest house and had no kitchen. The ruling upheld the district court’s judgment in favour of TNC.