Steven David Lunden v. The State of Wyoming, 297 P.3d 121

Lunden pled guilty on May 7, 2010 to unlawful use of a credit card (misdemeanor) and forgery (felony).
Sentences: not less than 30 nor more than 72 months for forgery; 6 months for misdemeanor; sentences ordered concurrent.
December 16, 2010: motion to modify based on not being allowed to withdraw guilty pleas and alleged inaccurate presentence history; denied.
January 5, 2011: motion to correct illegal sentence based on inaccurate presentence history; denied.
April 16, 2012: motion to correct illegal sentence, repeating prior claims; denied on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by denying a motion to correct an illegal sentence.	Lunden claims the sentence violated §7-11-507 because he was not advised about potential firearm disqualification.	State contends the issue is raised for the first time on appeal and should be barred by res judicata.	No consideration of merits; raised for first time on appeal and barred by res judicata; affirm.

Washington v. State, 261 P.3d 717 (Wy. 2011) (discusses when issues raised on appeal are barred for not raising below)
Erwin v. State, 237 P.3d 409 (Wy. 2010) (foundation for rule preventing new appellate arguments)
Moore v. State, 215 P.3d 271 (Wy. 2009) (res judicata principles in post-conviction context)
Gould v. State, 151 P.3d 261 (Wy. 2006) (res judicata application in Wyoming)
Taylor v. State, 74 P.3d 1239 (Wy. 2003) (direct-appeal viability for challenging guilty pleas)
Bird v. State, 39 P.3d 430 (Wy. 2002) (distinction between conviction challenges and sentence challenges)
Harlow v. State, 105 P.3d 1049 (Wy. 2005) (limitations on post-conviction relief for sentence claims)