Anadarko Land Corporation F/K/A Union Pacific Land Resources Corporation, a Nebraska Corporation, and Three Sisters, Llc, a Wyoming Limited Liability Company v. Family Tree Corporation, a Wyoming Corporation

[¶49] I respectfully dissent. I concur with the majority’s analysis of what makes a deed void rather than voidable, but I conclude that the application of the law to the tax deed at issue must result in finding the deed is void.

[¶50] There is no dispute that Article 15, § 3 of the Wyoming Constitution prohibits the taxation of minerals in place; and it meant the same thing in 1911, even though it may have been misunderstood at that time. To the extent there were statutes in 1911 which may have authorized taxation of minerals in place, they were unconstitutional. (See, e.g., Billis v. State,…