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Wood v. Board of County Commissioners of Fremont County

Wyoming Supreme Court

759 P.2d 1250 (Wyo. 1988)

Relevant factsFree

The Woods (plaintiffs) had conveyed land to Fremont County (defendant) 'for the purpose of constructing and maintaining thereon a County Hospital.' The county ran a hospital there for 35 years before selling the land and hospital to a private company, which operated it briefly before putting it up for sale. The Woods sued, arguing their original conveyance created either a fee simple determinable or a fee simple subject to a condition subsequent that should revert to them once the land stopped serving as a hospital. The lower court ruled for the county.

IssueFree

Whether language conveying land 'for the purpose of' a particular activity is sufficient to create a reversionary interest in the conveyor.

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