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Wyoming

UCC filings: Limited Land records: Moderate

No UCC fraud refusal; private false/frivolous-lien strike petition with damages floor What the badges mean

Last verified: July 27, 2026 — confirm current text on the official site; this date is not a promise the law is unchanged.

Specific items rechecked October 3, 2026: Tuttle v. Lee (scope limited to federal tax liens). October 14, 2026: Tuttle v. Lee ¶10 reasoning, from the official opinion.

General information, not legal advice. Confirm current fees, forms, and deadlines on official government sites, and talk to an attorney about your situation. LienGuardAI does not file anything for you. See Legal Disclaimer & Terms of Use.
Relevant case law: Facing a Wyoming federal criminal case, a defendant filed a “Commercial Just Compensation Customer’s Lien” with the Laramie County clerk purporting to encumber the property of the U.S. Attorney and the assigned district judge, supposedly to secure a planned civil-rights claim. The United States sued to clear the filings. The Tenth Circuit affirmed summary judgment releasing the liens and enjoining similar encumbrances, holding that the theory of a citizen “customer” lien on public officials has no basis in law and that judges and prosecutors are immune from the damages theories the papers claimed. Verified. (United States v. McKinley, 53 F.3d 1170 (10th Cir. 1995).) Separately, in a case about a federal tax lien, Wyoming’s Supreme Court held that a county clerk must record a properly certified federal tax lien notice and has no authority to consider its underlying basis or declare it invalid; the ruling is limited to federal tax liens. Verified. (Tuttle v. Lee, 2018 WY 104, 425 P.3d 998.)

This is a plain-language summary of a published judicial opinion, not a complete report of the case. Confirm names, holdings, and procedural posture against the opinion itself.

UCC financing statements

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Search Wyoming's UCC records

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Refusal / removal authority

Wyoming has no non-uniform UCC pre-filing fraud refusal authority identified — only uniform mechanical grounds.

Citations No non-uniform pre-filing authority ide…
Full citations
  • No non-uniform pre-filing authority identified

There is no pre-filing content/fraud review to invoke.

If it's already filed: Information statement / §34.1-9-518 / §34.1-9-625.

Real-property liens

Wyo. Stat. §29-1-601 (False or Frivolous Liens) is the live tool. Subsection (a) makes official-duty liens against public officials/employees invalid without a court order or authorizing statute. Subsection (b) lets any person whose real or personal property is subject to a recorded claim of lien petition district court to strike a lien that is invalid under (a), forged, or that the claimant knew was groundless / materially false — with damages of $1,000 or actual (whichever greater), costs, and fees. Subsections (c) (misdemeanor for harassing filings intended to intimidate officials) and (d) (official affidavit path) are officials-scoped. §6-3-410 is repealed and was never a fraudulent-lien statute. 2025 SF0011 (fraudulent documents to wrongfully possess property) failed and is not law. Tuttle v. Lee, 2018 WY 104, 425 P.3d 998, is narrow: it holds that a county clerk must record a properly certified federal tax lien notice and has no authority to judge its underlying basis or declare it invalid. Its reasoning (¶10) is stated in general terms: a county has only the powers granted by the state constitution or statutes, or reasonably implied from them, and that limit extends to county officers. But the court applied it only to the federal tax lien before it. It does not decide whether clerks can screen other kinds of liens.

Citations WY §29-1-601 WY Tuttle v. Lee, 2018 WY 104 (…
Full citations
  • Wyo. Stat. §29-1-601
  • Tuttle v. Lee, 2018 WY 104 (federal tax liens only)

Private owners have the §29-1-601(b) district-court petition (the statute sets the filing fee); officials also have the (d) affidavit. No clerk refusal based on underlying validity was confirmed.

If it's already recorded: Strike order + ≥$1,000 or actual damages + fees under (b); misdemeanor under (c) is officials-harassment scoped.

Real-property records are held by the county clerk where the property sits.

If the path runs through court

Wyoming doesn't have a self-filed administrative form for this — the verified remedy runs through a court, which generally means an attorney rather than a fill-in-the-blank document.

District-Court Petition to Strike a False or Frivolous Lien

Wyoming's dedicated private-owner tool is §29-1-601(b): a district-court petition to strike a recorded claim of lien that is invalid under (a) (official-duty without order/statute), forged, or that the claimant knew was groundless or contained a material misstatement or false claim. On success the court strikes/releases the lien and awards $1,000 or actual damages (whichever greater), costs, and reasonable attorney's fees. The (c) misdemeanor and (d) affidavit paths are for public-official targets.

This generally requires an attorney. The confirmed private-owner remedy is a district-court petition; this research found no administrative alternative for Wyoming real property. (Tuttle v. Lee concerns federal tax liens only.)
Citation WY §29-1-601

People consulting an attorney about a filing like this often bring:

  • A copy of the filing, if available, and where and when it was filed or recorded (office, date, and document or instrument number)
  • Any notices, letters, or other correspondence about it
  • Records for the property or account it names, such as a deed, title, or loan papers
  • Notes on any contact with the filer or the filing office, with dates
  • This page's citations and their check dates

How this usually works in Wyoming

A summary of the tools Wyoming law and filing offices provide — general information, not instructions for your facts. Confirm current practice with the filing office and talk to an attorney about your situation.

  1. 1Wyoming's UCC search requires an account or subscription (link on this page).
  2. 2Wyoming has no pre-filing UCC fraud refusal.
  3. 3For a forged, groundless, or knowingly false lien on private property, §29-1-601(b) provides a district-court petition to strike it. Subsections (c) and (d) are for public-official targets; §6-3-410 is repealed and 2025 SF0011 failed.
  4. 4No county-clerk refusal or removal power for private liens was confirmed in this research. (Tuttle v. Lee concerns federal tax liens only.)

What to expect

Wyoming is court-leaning on land records, but private owners do have a dedicated §29-1-601(b) strike petition with a damages floor — not just an officials-only tool. Confirm the current fee on the state's official site — filing and search fees change and are not published here.

Sources: the LienGuardAI fifty-state survey and UCC search portal review (How we verify). No dollar fee amounts are published here — always confirm the current fee on the state's own site.