Barlage v. Key Bank of Wyoming
In Barlage v. Key Bank of Wyoming, 892 P.2d 124 (Wyo. 1995), the Court determined discovery of water seepage, not discovery of the cause of the seepage, triggered the applicable statute of limitations.
The Court explained its decision:
"It is clear Barlage was first aware of water seepage into the crawl space in 1986. In endeavoring to avoid the statute of limitations, Barlage argues he was not aware he had a claim against Key Bank although he was aware of the invasion of the water. This contention is not consistent with Wyoming law which, in the area of tort injuries, can perhaps be summarized by the proposition that the occurrence of damage satisfies the requirement that the injured party knew or reasonably should have known of the potential of a wrongful act being the cause." (892 P.2d at 126-27.)