The Wyoming State Bar on Tuesday announced that the State Supreme Court has disbarred Leigh Anne Manlove, who was the county district attorney from 2019-2023. The disbarment will go into effect on May 5.
"Considering the aggravating and mitigating circumstances, the number of rule violations, the severity of the rule violations, Ms. Manlove's pattern of conduct and pervasive dishonesty, the effects of Ms. Manlove's conduct on the legal profession and the criminal justice system, and her state of mind, we conclude disbarment is the proper sanction," the court said in its Tuesday order of disbarment. "Ms. Manlove's conduct and lack of candor places her continued fitness to practice law into serious question and does not allow for any sanction short of disbarment."
She is also ordered to pay $32,410.21 to the Wyoming State Bar by June 1 for the Special Bar Counsel's fees and other administrative costs.
The order of disbarment followed an eight-day hearing held before the Wyoming State Bar's Board of Professional Responsibility (BPR) in February 2022. The BPR, the group that oversees the behavior of Wyoming attorneys, recommended that Manlove lose her license to practice law, saying she failed to competently fulfill the duties of her office.
Legal Reaction
Former Wyoming Attorney General Gay Woodhouse said the Supreme Court made the right decision.
"You hate to see this happen to somebody, this kind of career-killer," Woodhouse said. "We must live with the consequences of our actions."
Woodhouse said she knew Manlove for many years prior to her becoming district attorney. The district attorney in Laramie County handles all criminal prosecution and cases. Many county attorneys around the state lack a district attorney in their jurisdiction, so they must manage all cases including civil filings.
"I was glad they focused on the most egregious things," she told Cowboy State Daily.
There were many different violations cited in the courts 71-page decision, but the court dedicated most of its focus to the allegations Manlove violated her duties of competence and diligence.
Laramie County District Attorney Sylvia Hackl, Manloves successor, agreed with Woodhouse. Hackl ran in 2022 on the promise of improving the management of the district attorney's office.
"Based upon what I knew, from what was told to me by members of the bar and what I read in local media reports, I'm not surprised this is their (Supreme Court) decision," Hackl told Cowboy State Daily.
In its case against Manlove, the Wyoming State Bar's special counsel sought to remove Manlove from her duly elected office as the Laramie County District Attorney before the end of her term. This did not occur, but Manlove did not run for reelection last August.
Violations
The BPR determined Manlove violated her duties of competence and diligence, made misrepresentations to courts and to disciplinary counsel, and failed to comply with court rules and directives.
"In numerous instances, Manlove engaged in conduct prejudicial to the administration of justice," the announcement said.
The Supreme Court agreed with all of these findings.
The court also determined that Manlove's behavior negatively affected the public's perception of the criminal justice system and Laramie County Circuit Court when she attempted to place blame on law enforcement "for her own shortcomings," according to the State Bar. The court said she attempted to prevent the public from knowing about her failures by making false statements to the public and disciplinary counsel.
Manlove also gave two separate media interviews where she disparaged the Cheyenne Police Department's investigation of a particular case.
Woodhouse said she found this behavior especially egregious.
In her brief to the Supreme Court, Manlove argued that the BPR failed to pay enough attention to the witnesses testifying in her favor during the February hearing. She also argued that disbarment is too extreme a punishment for the allegations she faces.
Manlove was elected Laramie County's district attorney in 2018 and the day after she took over the office in 2019, fired most of her staff. The action left the office unable to conduct its duties, a BPR report said.
Former employees who worked under Manlove also testified to the panel that Manlove oversaw a hostile work environment in the office, leading to five attorneys, including the majority of the attorneys she hired at the beginning of her administration, quitting by the end of 2020.
During her tenure, Manlove dismissed at least 400 cases in circuit and district court, citing budget cuts as a reason. The BPR found her claims about the budget were exaggerated.
"The professional conduct of an attorney is so important," Woodhouse said. "You must always be honest. Its so important to be above board."
Laramie County's seven district and circuit court judges sent a letter to the Wyoming bar expressing concern over the way the office was being run in 2021. One judge who testified before the court said that motion to dismiss orders sent over from Manlove would pile up on his desk for weeks and months on end.
Handling Of Sexual Assault
Manlove was 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. In another instance, the state bar reported Manlove failed to inspect evidence related to a sexual assault case involving a 14-year old girl until more than seven months after all evidence had been brought to her office by the Cheyenne Police Department.
Manlove disparaged the police department's handling of this case in multiple media interviews.
The BPR accused Manlove of purposely making false statements about this case to its panel.
Not All Bad
The Supreme Court did acknowledge a number of mitigating factors that support Manlove taking the actions she did.
The court found that the "chaos" caused by the COVID-19 pandemic, coupled with budget cuts and a heavy caseload in Laramie County factored into her actions. They also found evidence that the previous administration left a stack of uncharged cases that contributed to her office's backlog.
The court found Manlove did take steps to improve her conduct after the judges sent their letter and the bar initiated its investigation, with evidence showing the office's work environment was improving.
Finality
In August, the Wyoming Supreme Court heard arguments for and against Manlove's disbarment. Hackl believes the court purposely waited until Manlove was out of office before rendering its decision against the former district attorney in order to avoid a vacancy appointment.
Woodhouse said Manlove appeared qualified for the job when elected and was a respected attorney upon beginning her tenure.
"I was just mystified by it," she said.
Woodhouse hopes the Supreme Court decision does not discourage members of the public from wanting to practice law and run for county and district attorney positions.
Hackl said her office is not considering bringing criminal charges against Manlove.
"I don't think there is any violation of criminal statute," Hackl said. "The certain actions taken by the Supreme Court are for me, a serious punishment that she will have to deal with."
