Guillermo Eduardo Gomez v. The State of Wyoming, 311 P.3d 621

Appellant pled guilty to conspiracy to deliver methamphetamine in December 2009 and received a 15–20 year sentence; AOAA labeled him a qualified offender and recommended intensive treatment.
Judgment and sentence were affirmed on direct appeal; Anders procedure allowed appointed counsel to withdraw.
In October 2011, appellant timely filed a motion for sentence reduction, which the district court denied; no appeal followed.
Two years after affirmance, appellant filed a second motion seeking modification or partial suspension; the district court denied as untimely under Rule 35(b).
Appellant argued AOAA allows modification without time limits since the offender is qualified and has completed treatment.
This Court held the AOAA does not create a separate right to modify a sentence; Rule 35(b) provides the sole avenue, with a one-year deadline.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court have jurisdiction over the motion to modify/reduce?	Appellant argues AOAA permits modification without time limits.	Gomez contends Rule 35(b)’s one-year deadline governs and AOAA does not create a separate avenue.	No jurisdiction; motion filed beyond one year.

Reese v. State, 910 P.2d 1347 (Wyo. 1996) (one-year limit governs reductions under Rule 35(b))
Tomlin v. State, 35 P.3d 1256 (Wyo. 2001) (jurisdictional timing for sentencing motions)
Eckdahl v. State, 264 P.3d 22 (Wyo. 2011) (timeliness of post-conviction relief)
Greene v. State, 214 P.3d 222 (Wyo. 2009) (statutory interpretation; AOAA purpose)
Anders v. California, 386 U.S. 738 (1967) (procedural default for counsel withdrawal on appeal)
Gomez v. State, 241 P.3d 502 (Wyo. 2010) (affirming conviction and sentence on direct appeal)