Disbar Manlove, panel formally recommends

CHEYENNE — In a formal report filed Friday, a panel charged with recommending disciplinary action against Laramie County District Attorney Leigh Anne Manlove reiterated its support for her disbarment. 
The 61-page document describes what it called a “broad range ... of misconduct” by Manlove. It was filed with the Wyoming Supreme Court, which oversees the Wyoming State Bar and its Board of Professional Responsibility. The BPR is the hearing body for attorney discipline in the state. 
“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 said. 
The district attorney “engaged in a pattern of neglect,” and she “improperly withheld material information and submitted false reasons for declining to charge cases,” the document continued. 
The report also recommended Manlove be required to pay an administrative fee of $3,000 and reimburse the State Bar for costs related to her disciplinary proceedings. 
Following the conclusion of a seven-day disciplinary hearing, the panel announced Feb. 11 that it would recommend Manlove be disbarred, or lose her ability to practice law in Wyoming, for violating six rules of professional conduct for attorneys in the state. 
These rules were found to be: Rule 1.1, duty of competence; 1.3, duty of diligence; 3.3(a), duty of candor to the tribunal; 3.4, duty to follow rules of the tribunal; 8.1(a), material false statements in a disciplinary proceeding; and 8.4(d), which says, “It is professional misconduct for a lawyer to engage in conduct that is prejudicial to the administration of justice.” 
The hearing was held in early February at Little America Hotel and Resort in front of a three-person panel chosen from the full Board of Professional Responsibility. Jackson-based attorney Christopher Hawks, who signed the report, served as the panel’s chairman. 
Formal charges filed by the Office of Bar Counsel last year with the State Bar alleged Manlove had mishandled the prosecution of cases in Laramie County and inappropriately dismissed certain cases, and that she created a hostile work environment for employees of the district attorney’s office, among other accusations. 
The state Supreme Court will ultimately decide what consequences Manlove will face as a result of the conduct laid out in Friday’s report. This process may take several months. 
Manlove’s attorney, Stephen Melchior, did not comment Friday on the submission of the report. Manlove and Melchior will have an opportunity to formally respond.
Following reading of the disbarment recommendation last month, Melchior told the Wyoming Tribune Eagle: “Until the Wyoming Supreme Court acts, Leigh Anne Manlove will continue to serve as the Laramie County district attorney, and she’s committed to serving the citizens of Laramie County as long as she remains in office.” 
Throughout the report, the panel outlined multiple examples of each rule violation by Manlove. These included exaggerating the impact of budget restraints, leading to the dismissal of hundreds of cases she attributed to budget cuts. 
Following the announcement of these planned cuts by Gov. Mark Gordon, the district attorney said her office expected to no longer prosecute non-priority cases (priority cases included violent felonies, domestic violence cases, subsequent DUIs and felony drug crimes) or certain traffic violations. The report said she “categorically refused to prosecute Game and Fish violations.” 
Vacancies during this time “eclipsed” the need for employee furlough days, Wyoming State Budget Department Director Kevin Hibbard testified, but employees were required to take furlough days anyway. 
The Natrona County District Attorney’s Office, characterized in the report as the “second busiest district in the state,” dealt with “relatively minor impacts” from the temporary 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%,” Friday’s report said. 
The document said the “chaotic” environment of Manlove’s office, and “the pervasive atmosphere of fear and intimidation emanating from Ms. Manlove,” led to “poor office performance,” “overwhelming stress” and consistently too few employees to handle the workload. Except for a brief period in spring 2020, the district attorney’s office “was, and remains, chronically understaffed.” 
Also at issue was Manlove’s conduct surrounding the Andrew Weaver case. 
Within a few days of Weaver’s release from jail – caused by an employee of Manlove’s office failing to file documents in time – he shot and killed two people, and injured two teenagers. 
A news release later issued by Manlove gave “a plainly false account” of what happened, the report said, including that the Laramie County Circuit Court had been closed that week, preventing her office from filing the paperwork necessary to keep Weaver in jail. 
The report noted a repeated failure to access crime lab data in the case of an alleged child sex abuse victim, which was referred to the Wyoming Attorney General’s Office in January, and a failure to provide evidence in a 2019 case, resulting in the dismissal of a case against a man charged with violent felonies. 
Other professional conduct violations outlined in the report include Manlove “promoting” the idea of individual law enforcement officers prosecuting criminal matters, filing improper motions to dismiss cases after judges warned her to stop, directing staff not to report overtime and failing to take prompt action to fill vacancies in her office. 
The report pointed out that district attorneys in Wyoming “are required to have been licensed for at least four years and to be members in good standing of the (Bar) immediately prior to election.” 
“(Manlove’s) claims that there was a ‘coordinated effort to remove her from office’ was false, given that once elected, Wyoming law does not require a district attorney to be licensed and in good standing with the (Bar),” the report explained. “The panel finds this to be evidence of (Manlove’s) fundamental lack of understanding of the law governing her position as Laramie County District Attorney.” 
Manlove’s defense, it continued, “consisted almost entirely of blaming the allegations against her upon the shortcomings of others.” 
“The panel finds no factual basis for such claims, which must give way to the overwhelming body of testimony and evidence presented of incompetence, lack of diligence and dishonesty by Ms. Manlove, which contributed to a wholesale failure to competently discharge her duties as an elected official,” the report said. 
The panel noted that it was “disappointed” by Manlove’s conduct before and during the hearing. 
This included testifying under oath that she believed the Office of Bar Counsel, the seven Laramie County District Court and Circuit Court judges, her former employees and the panel itself may have been part of a coordinated effort to remove her from office, because they either did not like her personally or did not agree with her policies. There was no evidence presented during the hearing to back up these claims, the report stated. The claims undermined her defense, “as well as the reliability and credibility of her testimony,” the panel wrote. 
Manlove also conducted radio interviews and issued press releases claiming similar things, saying the process was unconstitutional and she already knew what the panel’s decision would be, and disparaging former employees. 
Less than two weeks before the disciplinary hearing began, she endorsed and shared a GoFundMe campaign to “Fight Cancel Culture in Laramie County” and raise money for her defense. 
Despite this behavior, the report said, the panel only based its findings and recommendations on testimony and evidence, but these actions showed Manlove’s “continued refusal to acknowledge and to take responsibility for her misconduct.” 
Manlove’s testimony “was not credible or believable in numerous respects,” the report said, as she was “unwilling or unable to answer direct questions from (the Bar’s representation, Special Bar Counsel Weston W. Reeves) as well as panel members” and “exhibited a combative and defiant attitude.” 
The panel said it was “incredulous” that Manlove testified she had not read much of the evidentiary material produced for her disciplinary hearing. 
“This is indicative of how she ran her office and her cavalier attitude toward these proceedings, and her belief in its ‘preordained conclusion,’” the report went on to state. 
If the state Supreme Court decides to disbar or suspend Manlove from practicing law while she still holds the office of district attorney, “she would not be able to appear in court, argue cases, do anything that a lawyer does,” Bar Counsel Mark Gifford said in an interview last month immediately following the panel’s disbarment recommendation. 
Manlove’s term will be up in January 2023, unless she is re-elected in November. 
The district attorney will have 30 days to respond with an objection, Gifford explained at the time. Reeves will then have 30 days from that filing to enter his response. 
The court may grant extensions to either party. A decision by the Supreme Court may take several months. The court could decide to set the case for oral arguments, Gifford said, which likely wouldn’t happen until fall. 
The court took close to nine months to decide on a punishment for Becket Hinckley, a former Teton County prosecutor who was suspended from practicing law in Wyoming for three years. 
A State Bar hearing panel had recommended Hinckley be disbarred after it found he violated seven rules of professional conduct in a 2015 aggravated assault trial, according to reporting by the Casper Star-Tribune. 
The Manlove hearing was just the second of its kind, following a rule change in September 2019 that required documents and information related to Bar disciplinary proceedings be available to the public. 
Hinckley’s May 2021 disciplinary hearing was the first conducted in public. Gifford has declined to comment on the outcome of the hearing or the hearing itself.
 
This story was published on March 12, 2022.