Banzhaf v. Swan Co

In Banzhaf v. Swan Co., 60 Wyo. 201, 148 P.2d 225, 228 (1944), involving state land lease renewals, the Court interpreted a provision of the applicable statutes providing for de novo judicial review of administrative action as follows: "The trial "de novo" as mentioned in Section 91-306, W.R.S.1931, is simply limited to a determination on the part of the District Court whether on the facts proven there was "an illegal exercise" of the Board's discretion, a case of fraud, or a "grave abuse of such discretion." Unless one of these three elements should appear the action of the Board should not be disturbed."