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Wyoming – Accord and Satisfaction

According to Wyoming courts, an “accord” is an agreement whereby one party undertakes to give or perform and the other to accept, in satisfaction of a claim, liquidated or in dispute, and arising either from contract or from tort, something other than or different from what s/he is, or considers himself/herself, entitled to; and a “satisfaction” is the execution, or performance of such an agreement.[i]

A party’s acceptance of a check in an amount less than that claimed and expressed to be in full payment constitutes an accord and satisfaction notwithstanding any restriction or protest placed upon the check by the payee, where a claim is unliquidated and in dispute.[ii]


[i] Casper Nat’l Bank v. Woodin, 68 Wyo. 232 (Wyo. 1951)

[ii] Jahn v. Burns, 593 P.2d 828 (Wyo. 1979)

Inside Wyoming – Accord and Satisfaction