Hickman v. Groves
In Hickman v. Groves, 2003 WY 76, 71 P.3d 256 (Wyo. 2003), the Court concluded a genuine issue of material fact existed regarding whether the term "oil rights" as used in the Hickman/Willard deed had a particular trade usage at the time and place of the deed's execution.
The Court stated: "...circumstances known to the parties at the time they entered into the contract, such as what that industry considered to be the norm, or reasonable or prudent, should be considered in construing a contract, while the parties' statements of what they intended the contract to mean are not admissible."
Thus, the Court directed the district court to consider the circumstances surrounding execution of the deed to determine whether "oil rights" was a term of widely known custom and usage in Campbell County in the 1940s which included the "gas rights" without specifically mentioning the word "gas."