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Salzburg v. Dowd

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At issue in Salzburg was Johnson County, Wyoming’s attempted termination of a perpetual conservation easement that had been conveyed to the County in 1993 as a
tax-deductible charitable gift. In 2002, at the request of new owners of the land (the Dowds), the County executed a deed transferring mthe easement to the Dowds, intending to thereby terminate the easement. A County resident (Hicks)  led suit alleging, inter alia, that the easement was held in trust for the benefit of the public and could be terminated only in a cy pres proceeding. In 2007, the Wyoming Supreme Court dismissed the case on the ground that Hicks did not have standing, but invited the Wyoming Attorney General (AG), as supervisor of charitable trusts, “to reassess his position” with regard to the case.

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