Former District Attorney Disbarred for Unprecedented Mass Dismissal of Hundreds of Cases and Drastic Reduction in Services

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Former Laramie County District Attorney Leigh Anne Manlove has been disbarred and ordered to pay over $32,000 in fees and costs after she dismissed about 400 cases, including one in which the defendant was already serving a sentence and another where a defendant was awaiting sentencing after a guilty plea. The Wyoming Supreme Court approved her disbarment in an opinion published on April 4. The district attorney’s office reportedly had problems managing the caseload from the beginning of Manlove’s tenure in January 2019, partly because she fired five out of six lawyers who remained in the office when she took over. The office should have had ten lawyers when fully staffed. The four new attorneys that Manlove hired had difficulty getting up to speed, with one testifying in Manlove’s disciplinary hearing that he had to work 18-hour days during the week and several hours on weekends. Some employees reported that the “work environment was hostile” and difficult, with attorneys leaving to find new jobs. Five lawyers had left the office by the end of 2020.

Manlove reacted negatively when she learned that the Wyoming governor was ordering agencies to reduce budgets by 6% during the COVID-19 pandemic, and she made preparations for budget cuts. Still, she was later informed that vacancies in her office made them unnecessary. That did not stop her from email declaring that her office would primarily become “a felony-only prosecutor’s office,” according to the state supreme court. Manlove then proceeded to dismiss around 400 cases, citing budgetary reasons. One judge testified that “cases just being dismissed, dismissed, dismissed” day after day and week after week. The Wyoming Supreme Court said that Manlove “exaggerated the impact of budget restraints” and “prematurely directed the wholesale dismissal of cases without considering the merits of each case.” The court added that Manlove unjustifiably made a drastic reduction of the services historically and statutorily required to be provided by the D.A.’s office.

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The court also cited Manlove’s mishandling of two cases, one where she failed to turn over DNA test results to a sexual assault and kidnapping defendant promptly, resulting in the exclusion of the evidence and dismissal of the case, and the other where she delayed reviewing reports in the case of a 14-year-old girl who reported that her mother’s boyfriend was sexually abusing her. She then blamed the police for failing to notify her about case documents. According to the state supreme court, Manlove also issued a press release falsely blaming court closures for her office’s failure to file the correct documents against a suspect before he was released from a 72-hour hold. The suspect shot four people, killing two of them.

The Wyoming Supreme Court concluded that Manlove demonstrated a pattern of misconduct, dishonest or misleading statements, and a refusal to accept accountability. Mitigating factors included “two great losses” that Manlove suffered in fall of 2019 and 2020, the chaos caused by the pandemic, the heavy caseload in Laramie County, and evidence that the prior administration left “a stack of uncharged cases,” the state supreme court said. Manlove did not immediately reply to an email and voicemail message seeking comment.