Laramie County’s district attorney has failed to competently carry out the duties of her office and has consistently blamed that failure on others, according to a report issued by the group that oversees attorneys.
The Board of Professional Responsibility said in its formal report on the February hearing of Leigh Anne Manlove that her actions have hurt the cause of justice in Laramie County, leading to its recommendation to the Wyoming Supreme Court that she be barred from practicing law.
“Considering the broad range of Ms. Manlove’s misconduct and its impact upon the administration of criminal justice in Laramie County, the hearing panel finds that the presumptive discipline … is disbarment,” said the report, which was released Friday.
“Ms. Manlove’s course of conduct clearly demonstrates that she does not understand the most fundamental legal doctrines or procedures, and such conduct caused serious injury to the administration of criminal justice in Laramie County,” the report added.
The hearing stemmed from formal complaints filed against Manlove by the Office of Bar Counsel, the individual charged with looking into allegations against attorneys.
The first formal complaint was filed against Manlove in June 2021 and was prompted in part by a letter by all seven of Laramie County’s judges expressing concern about her performance.
Among other things, she was accused of exaggerating budget pressures faced by her office to justify the dismissal of hundreds of cases in circuit and district court. She was also accused of misrepresenting the facts surrounding the case of a man accused of killing two people five days after being released from police custody because of a procedural error.
Manlove will be allowed an opportunity to respond to the report before it is submitted to the Wyoming Supreme Court for its decision.
In the months leading up to the hearing, Manlove alleged the disciplinary process was the result of a concerted attempt to remove her from office.
The BPR, however, rejected the argument said it showed a pattern on Manlove’s part to blame others for the problems in her office.
“The spectacle (Manlove) has turned this proceeding into, complete with talk radio interviews … and press releases, has created an unfortunate and unnecessary diversion from the issues before this panel,” the report said. “Simply put, it evidenced (Manlove’s) continued refusal to acknowledge and to take responsibility for her misconduct.”
The report also noted that under Wyoming law, it is doubtful Manlove could be removed from office, even if she were disbarred.
Manlove was elected in 2018 and took over the office on Jan. 8, 2019, when she fired all but one of the office’s seven lawyers. While five new lawyers were added to the staff by February of 2019, the report said the firings and later turnover continues to leave the office “chronically understaffed.”
The resulting dismissal of about 700 cases was the result of understaffing, the report said, not budget cuts.
“The panel finds that Ms. Manlove unnecessarily seized upon a 6% budget cut to prematurely and arbitrarily reduce the services performed by her office by more than 50%,” it said.
Manlove also did not accurately explain why she took certain actions, the report said.
“Ms. Manlove engaged in a pattern of neglect, thereby causing serious injury to the administration of criminal justice on Laramie County,” it said. “Ms. Manlove improperly withheld material information and submitted false reasons for declining to charge cases.
“In this regard, Ms. Manlove intended to deceive the court, making numerous false statements, published numerous false documents, and caused injury to the administration of justice in Laramie County,” it added.