The Wyoming Supreme Court affirmed a district court's award of prejudgment interest to a construction company in a contract dispute involving unpaid work on a custom home. In *Russ Ropken and Debi Ropken v. YJ Construction, Inc.* (Wyo. 2025), the high court rejected the homeowners' challenge to both the interest award and the procedural manner in which it was granted.
The case arose from a 2021 construction agreement between the Ropkens and YJ Construction for the building of a custom home. According to court records, YJ began construction in September 2021 based on an oral agreement with the homeowners. The contractor submitted regular invoices for services performed and materials provided, which the Ropkens initially paid.
However, the payment arrangement eventually broke down, leading YJ Construction to file a lawsuit seeking compensation for unpaid work. The matter proceeded to trial, where a jury determined that the Ropkens had indeed failed to pay YJ Construction for the partial construction of their custom home. The jury awarded damages to the contractor for the unpaid work.
Following the jury verdict, YJ Construction requested that the district court award prejudgment interest at the statutory rate. The district court, presided over by Judge Bobbi Dean Overfield of Park County, granted the request without conducting an evidentiary hearing. This decision prompted the Ropkens to appeal to the Wyoming Supreme Court.
On appeal, the Ropkens raised two primary arguments against the prejudgment interest award. First, they contended that the district court erred in awarding prejudgment interest at all. Second, they argued that their due process rights were violated when the court granted the interest award without conducting an evidentiary hearing on the merits of the request.
The Wyoming Supreme Court, in an opinion authored by Justice Hill, consolidated the Ropkens' arguments into two main issues: whether the district court erred in awarding prejudgment interest, and whether the court violated the defendants' due process rights by awarding the interest without an evidentiary hearing.
After reviewing the case, the Wyoming Supreme Court affirmed the district court's decision in its entirety. The court found that the award of prejudgment interest was proper under Wyoming law and that no due process violation occurred when the district court granted the interest without conducting a separate hearing.
The case highlights important principles in construction contract law, particularly regarding the recovery of prejudgment interest in disputes involving unpaid construction work. Prejudgment interest serves to compensate creditors for the time value of money between when a debt becomes due and when it is actually paid or adjudicated.
Under Wyoming law, prejudgment interest may be awarded at the statutory rate when certain conditions are met. The interest is designed to prevent debtors from benefiting by delaying payment of valid debts and to ensure that creditors are made whole for the period during which they were deprived of the use of their money.
The procedural aspect of the case also carries significance for future litigation. The court's finding that no evidentiary hearing was required for the prejudgment interest award suggests that such awards may be appropriate based on the existing record in cases where the underlying debt has been established through trial.
The Ropkens were represented by M. Jalie Meinecke of Meinecke & Sitz, LLC in Cody, Wyoming. YJ Construction was represented by Scott Stinson of Stinson Law Group, P.C., also in Cody. Both attorneys presented oral arguments before the Wyoming Supreme Court.
The case was decided by the full Wyoming Supreme Court, including Chief Justice Boomgaarden and Justices Gray, Fenn, Jarosh, and Hill. The unanimous decision reinforces existing precedent regarding prejudgment interest awards in contract disputes.
For construction contractors, the ruling provides reassurance that Wyoming courts will enforce payment obligations and award appropriate interest when clients fail to pay for completed work. The decision also confirms that procedural shortcuts may be available for interest awards when the underlying facts have been established through trial.
The case serves as a reminder to property owners of the importance of meeting payment obligations under construction contracts. When disputes arise, the potential for prejudgment interest awards adds additional financial consequences beyond the original contract amount.
This decision is subject to formal revision before publication in the Pacific Reporter Third. The Wyoming Supreme Court has requested notification of any typographical or formal errors for correction before final publication.