Former district attorney disbarred for 'mass dismissal' of hundreds of cases, 'drastic reduction' in services
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A former Laramie County, Wyoming, district attorney has been disbarred following her “mass dismissal” of about 400 cases, including a case in which a defendant was already serving his sentence and another case in which a defendant was awaiting sentencing after entering a guilty plea.
The Wyoming Supreme Court approved disbarment in an April 4 opinion and ordered former District Attorney Leigh Anne Manlove to pay more than $32,000 in fees and costs.
Manlove took office in January 2019. The district attorney’s office was having difficulty managing the caseload from the very beginning, according to the Wyoming Supreme Court’s opinion.
Part of the problem stemmed from Manlove’s decision to fire five out of six lawyers who remained in her office when she took over. The office should have 10 lawyers when fully staffed. The four new attorneys she hired had difficulty getting up to speed.
“Getting your arms around a thousands-of-case caseload was quite a pill to swallow,” one of the newly hired attorneys testified in Manlove’s disciplinary hearing.
The lawyer recalled working 18-hour days during the week and several hours on weekends.
Some employees reported that the “work environment was hostile” and difficult. Attorneys began looking for new jobs. Toward the end of 2020, five lawyers left the office.
Manlove reacted negatively when she learned that the Wyoming governor was ordering agencies to reduce budgets by 6% during the COVID-19 pandemic. There was also the possibility of more cuts in the future. Manlove made preparations but was later informed that vacancies in her office made it unnecessary to implement the initial round of cuts.
That didn’t stop Manlove from sending an email declaring that her office would primarily become “a felony-only prosecutor’s office,” the state supreme court said. Manlove proceeded to dismiss about 400 cases, citing budgetary reasons.
“Day after day, week after week,” one judge testified, “cases just being dismissed, dismissed, dismissed.”
Manlove “exaggerated the impact of budget restraints,” the Wyoming Supreme Court said, “and prematurely directed the wholesale dismissal of cases without considering the merits of each individual case, as evidenced by her filing of motions to dismiss in matters the defendant had already pled to the charge or had been convicted. We further agree Ms. Manlove unjustifiably made a drastic reduction of the services historically and statutorily required to be provided by the D.A.’s office. …
“Dismissing approximately 400 cases due to a backlog caused by her own decision-making and falsely citing budgetary reasons to conceal her gross mishandling of her office’s caseload reflects negatively on the legal profession, impairs public confidence in the justice system, fails to ensure justice is done, and engenders a disrespect for the judicial system.”
The state supreme court also cited Manlove’s mishandling of two cases. In one, she failed to turn over DNA test results to a sexual assault and kidnapping defendant in a timely manner, resulting in exclusion of the evidence and dismissal of the case. In the other, 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 police for her failing to notify her about case documents.
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 state supreme court said. The suspect shot four people, killing two of them.
The Wyoming Supreme Court concluded that Manlove demonstrated a pattern of misconduct, a pattern of dishonest or misleading statements, and a refusal to accept accountability.
Mitigating factors included “two great losses” that Manlove suffered in fall 2019 and fall 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.
Hat tip to the Wyoming Tribune Eagle and the Cheyenne Post, which covered the disbarment.
