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Hein v. Carlson extends Wyoming’s meander line rule to private deeds

Wyoming · Courts

Hein v. Carlson extends Wyoming’s meander line rule to private deeds

What happened. The Wyoming Supreme Court held, for the first time, that the meander line rule applies to private conveyances as well as government ones. In a riverfront subdivision, that puts the lot boundary at the thread of the river rather than at the surveyed line drawn on the plat — and the Court treated the subdivision’s recorded covenants as evidence of what the developer intended.

The case

Ronald W. Hein and Linda M. Hein v. Steven Paul Carlson and Paulette Joan Carlson; and Clarence Lee Daniels and Mary Jo Daniels, 2026 WY 33, docket S-25-0168, was decided March 10, 2026. Justice Gray wrote for a unanimous Court; the judgment was affirmed.1

The land is Red Butte Subdivision No. 2 in Natrona County, on the North Platte River. The dispute was over the “meander land” lying between the 1935 government-survey meander line — the lots’ platted northern edge — and the present thread of the river. The owners, the Court noted, “have historically considered and used [it] as an extension of their backyards” (¶ 4).

The new rule

“[¶ 14] This Court has not expressly held the meander line rule applies to private conveyances. We see no reason to depart from the generally recognized principle that the meander line rule ‘applies to government and private surveys alike.’ … Accordingly, whether a conveyance is from the United States Government or a private party, unless the language of conveyance clearly and unequivocally manifests an intent to fix a riparian boundary to the precise course specified in a property description, a riparian boundary specified or depicted in the conveyance as a meander line will establish a boundary at the natural shore of the body of water.”

And the result, in one line: “[¶ 28] … The property line between the parties’ lots in Red Butte and Park 10 is the thread of the North Platte River.”

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The covenants were read as boundary evidence

The part of the opinion that reaches associations is not the boundary holding but how the Court got there. Among the evidence of the developer’s intent, it cited the subdivision’s own recorded restrictions:

“[¶ 26] … This view is supported by Red Butte’s covenants and restrictions which contain conditions for restrictions on ‘lake front, stream or river front properties’ including limitations on constructing docks and ‘[s]urface launching gear.’”

A covenant drafted to regulate docks and boat launches is, on this reading, an admission that the developer thought the lots reached the water. The restriction did more work as evidence of title than it ever did as a rule of conduct.

What it displaces

Wyoming had applied the meander line rule to conveyances from the United States since Johnson Irrigation Co. v. Ivory, 46 Wyo. 221, 24 P.2d 1053 (1933), but had never said it reached a deed between private parties. Hein confirms Jourdan v. Abbott Construction Co., 464 P.2d 311 (Wyo. 1970), and Wilson v. Lucerne Canal & Power Co., 2007 WY 10, 150 P.3d 653, and distinguishes Glover v. Giraldo, 824 P.2d 552 (Wyo. 1992).

The plat statute did not fix the line

The losing argument was that W.S. § 34-12-102, the plat statute, makes the platted line the boundary. The Court rejected it at ¶ 23. A recorded plat can depict a meander line without freezing the boundary to it; only conveyance language that “clearly and unequivocally manifests an intent to fix a riparian boundary to the precise course specified” does that.

Why a waterfront Wyoming subdivision is affected

Three consequences follow from the boundary sitting at the thread rather than the platted line, and each is descriptive of the legal position rather than a prediction about any dispute:

  • The acreage is private, not orphaned. Where a subdivision plat shows lots bounded by a meander line on a river, the strip between that line and the water belongs to the riparian lot owners absent clear contrary language — not to the association, the developer’s residue, or nobody.
  • The boundary moves. A thread-of-the-stream line follows the water. Accretion and reliction change the acreage; a platted line does not.
  • Covenant language about water frontage carries beyond its own subject matter. Dock, launch, bank-stabilisation and setback provisions describe what the drafter assumed the lots included.

Wyoming has no general planned-community statute, so a subdivision’s recorded declaration and plat do nearly all the work. Hein is a reminder that the two documents are read together, and that the declaration can decide a question the plat appears to have settled.

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  1. Hein v. Carlson, 2026 WY 33, No. S-25-0168 (Wyo. Mar. 10, 2026) — opinion PDF, Wyoming Judicial Branch ↩
  2. Wyo. Stat. § 34-12-102 (plats; effect of recording) — compiled Title 34, Wyoming Legislative Service Office ↩

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