Thomas Gilcrease Foundation v. CavallaroAnnotate this Case
Plaintiff filed a declaratory judgment action against the Teton County Assessor seeking a declaration that the trusts for which it acted as trustee were charitable trusts within the meaning of Wyo. Stat. Ann. 4-10-406(a) and were exempt from taxation under Wyo. Stat. Ann. 39-11-105(xix). The district court dismissed the complaint, concluding that the primary jurisdiction doctrine made dismissal of the action appropriate. The Supreme Court affirmed, holding (1) because Plaintiff failed to exhaust its administrative remedies before filing a complaint in the district court, the district court properly dismissed the complaint; and (2) to the extent Plaintiff may have properly invoked the district court’s jurisdiction the district court did not abuse its discretion in concluding that the primary jurisdiction doctrine warranted dismissal of the action in favor of review through the administrative process.