In Bailey v. State, 12 P. 3d 173 (Wyo. 2000), the Court ruled that a conditional plea of guilty does not provide carte blanche permission for the appellant to present any and all arguments on appeal. 12 P. 3d at 177-78. Instead, the appellant may only raise those issues on appeal which were clearly called to the attention of the district court. Id. In other words, "we will not consider non-jurisdictional issues on appeal unless they have been raised before the lower court with at least a minimum effort to present a cogent legal argument." Bailey, 12 P. 3d at 178.