ECKDAHL v. State, 2011 WY 152

Eckdahl was convicted in Wyoming state court of possession with intent to deliver and sentenced to 2–4 years concurrent with a federal 70-month sentence.
Plea agreement stated the state sentence would not exceed the federal sentence and allowed a potential state-sentence reduction if the federal sentence was subsequently reduced.
The district court orally and in writing implemented a 2–4 year state term concurrent with the federal term, with possibility of modification if the federal sentence was reduced.
Eckdahl filed multiple post-sentencing motions: a premature first motion, a second untimely motion for reduction, a petition for reconsideration, and a third untimely motion for reduction.
The district court denied the second and third motions as untimely or lacking jurisdiction; Eckdahl appealed the denial of reconsideration and the third motion.
This Wyoming Supreme Court dismissed the appeal for lack of subject-matter jurisdiction because the challenged motions were untimely and reconsideration requests were not authorized by law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did State breach plea agreement entitling withdrawal of plea?	Eckdahl argues reduced federal sentence warrants state reduction.	State allegedly opposed his reductions contrary to the plea.	No breach; no entitlement to reduction since federal sentence never fell below 2–4 years.
Did defense counsel breach obligations to Eckdahl?	Counsel failed to protect Eckdahl's right to a sentence reduction.	No basis shown; plea terms and subsequent orders governed relief.	No reversible error; no breach established given the plea terms.
Were Eckdahl's due process rights violated?	Procedural protections were not afforded in denying relief.	Proceedings complied with applicable rules; no due process violation shown.	No due process violation found.
Did Court's failure to appoint appellate counsel deny meaningful access to law and courts?	Appointment of appellate counsel is needed for post-conviction relief.	No constitutional or statutory requirement for counsel in post-conviction motions.	No right to appointed counsel for post-conviction motions; access not violated.

Plymale v. Donnelly, 125 P.3d 1022 (Wyo. 2006) (motions for reconsideration not authorized; nullities)
Tomlin v. State, 35 P.3d 1255 (Wyo. 2001) (untimely post-sentencing motions lack jurisdiction)
Stewart v. State, 654 P.2d 727 (Wyo. 1982) (lack of jurisdiction bars appeal)
Pearl v. State, 996 P.2d 688 (Wyo. 2000) (Sixth Amendment right to counsel; post-conviction context)
Patrick v. State, 108 P.3d 838 (Wyo. 2005) (counseling and post-conviction considerations in Wyoming)
Gould v. State, 151 P.3d 261 (Wyo. 2006) (post-conviction counsel considerations)