Starter Removel

Is it corroded to the stud? Try some heat and penetrating oil and maybe a little persuasion, to knock the corrosion loose. Also be really sure you have all the fasteners loose before you muscle it.

I also have a 98 dodge dakota and had to replace the starter last year and had the same problem with that bolt you have very little room to work with but if you can try to get the box end of the wrench on there and hit the wrench with a hammer that what i had to do