Hurst v. Davis
In Hurst v. Davis, 386 P.2d 943 (Wyo. 1963), the landlord sought to eject a tenant from his property and collect $ 600 in unpaid rents. Id. at 943-45.
At that time, exclusive jurisdiction for forcible entry and detainer suits lay in the justice of the peace courts. Id.
The justice of the peace court's monetary jurisdiction was, however, limited to $ 200. Id. at 950.
The Court recognized that the legislature's principal objective in enacting the forcible entry and detainer statutes was to give landlords a summary remedy against tenants who hold over after their tenancy has expired. Id. at 949.
The legislature did not intend to deny a landlord, who was owed more than $ 200 in rent, the opportunity to use the abridged procedure provided in the forcible entry and detainer statute. Id.
The Court recognized, however, that the legislature had placed a monetary limit on the justice of the peace court's jurisdiction.
In resolving this "conundrum," the Court stated that, although a judgment by the justice of the peace court for an amount of rent due in excess of its monetary jurisdiction would be erroneous, "a mere finding of the amount of rent due, even though that amount be in excess of the jurisdictional limitation" would be lawful. Id. at 950.
Thus, the justice of the peace court could order that the tenant vacate the property, find the amount of rent due, and award the landlord a judgment for unpaid rent up to the amount of its statutory jurisdiction. Id.