Green River Dev. Co. v. FMC Corp
In Green River Dev. Co. v. FMC Corp., 660 P.2d 339, 348-51 (Wyo. 1983), the Court considered whether a permit to appropriate water was a "water right" when the permit waters had never been put to beneficial use.
The court held that a permit "is the necessary first step" in obtaining a water right, but that without an application to beneficial use, it was not a water right itself and therefore its use could not be changed. Id. at 348-51.