The Town of Jackson regime

Jackson’s ordinance, effective January 1, 2024 and unchanged since, is the tightest numerical cap in Wyoming. In residential zones a short-term rental is limited to:

• Three separate stays per calendar year, and
• 60 total rental nights per calendar year,

and requires a basic use permit and a business licence, both renewed annually. There is no 2025 or 2026 amendment to it.

What state law contributes: nothing

Wyoming has no short-term rental statute. No 2024, 2025 or 2026 enrolled act contains the phrase “short-term rental” or “short term rental” — a sweep of all 396 session laws across those three sessions returns zero. There is no state preemption of local regulation, and there is no state limit on what an association’s covenants may say about rentals.

In a state containing Jackson, Teton Village, Cody and the Yellowstone gateway, that is a conspicuous absence, and it is not accidental: no STR bill was filed in either session.

What Wyoming does impose is tax. Stays under 30 continuous days carry the 4% state sales tax, the mandatory 5% statewide lodging tax and an optional local lodging tax of up to 2%, under W.S. §§ 39-15-101(a)(xiv), 39-15-103(a)(i)(G) and 39-15-104, with a Department of Revenue sales tax licence required.

The covenant is a separate and independent question

A permit satisfies the county. It does not satisfy the declaration, and the Wyoming Supreme Court has said so twice in eighteen months.

In Schroth v. Kirk, 2025 WY 24, a Teton County winery operating under a county conditional use permit was enjoined for violating a single-family residential covenant. The Court, at ¶ 31: “Although Teton County may have authorized some of these activities, that approval does not override or excuse a violation of the Covenants.” And at ¶ 33, that the board, president and design committee “did not have the authority to override or amend the Covenants” — only a 70% written vote of lot owners could do that.²

The corollary runs the other way too. In Rafter J Ranch Homeowner’s Ass’n v. Stage Stop, Inc., 2024 WY 114, an association sued its own lot owner over a commercial use and lost, because the covenant for that lot permitted “any commercial purpose.” The document decides.

Three practical features of the Teton arrangement

• A written association approval is a document the association produces. Where the declaration is silent on rentals, or where the board’s authority to give or withhold such approval is not spelled out, the permitting requirement asks the association for something its own documents may not describe how to give.
• A county permit issued on the strength of an association approval does not amend the covenants. On Schroth, neither does the approval itself.
• Enforcement is not exclusive. The county enforces its regulation; the association or, where the declaration allows, any lot owner enforces the covenant. The two proceed independently and reach different remedies — abatement and daily fines on the county side, injunction and fee awards on the covenant side.

Everywhere else in Wyoming

No Wyoming community outside Teton County produced a short-term rental dispute involving covenants in the news during 2025 or 2026. Casper requires a business licence for short-term rental operation and its council has discussed occupancy limits, safety requirements and taxation without adopting a 2026 ordinance. Cody’s existing rules originate in fire-department safety inspections and a city business licence. Gillette, Sheridan and Laramie adopted nothing in 2026 that reaches the subject.