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CHEYENNE —– In her formal response to a charge made by the Wyoming State Bar alleging “incompetence and lack of professionalism,” Laramie County District Attorney Leigh Anne Manlove rejected that any behavior described by special bar counsel was improper based on professional conduct rules, asking for the charge to be dismissed.

“The Formal Charge, and each and every allegation therein, fail on their face to reasonably reflect proof by clear and convincing evidence” that the district attorney violated any of the rules pointed out by the State Bar, she wrote in the documents filed Tuesday with the State Bar’s Board of Professional Responsibility.

Manlove also rejected the suggestion that one of three investigations undertaken by the State Bar was prompted by an “unprecedented” letter signed by all of Laramie County’s district and circuit court judges.

In the letter, the seven judges voiced their concern about the district attorney’s ability to carry out her duties and provide adequate representation for Laramie County citizens.

Instead, Manlove said she believes the investigation was motivated by the Wyoming Supreme Court’s rejection of a petition by Wyoming State Bar Counsel Mark Gifford to immediately suspend her as an attorney.

Her response includes this petition by Gifford, dated Dec. 22, in which he cites the judges’ letter and examples of Manlove’s conduct. The other two investigations came after complaints from mothers of women who were victims of dangerous crimes “perpetrated by men whose return to the community (without the period of incarceration their crimes warranted) was later endorsed by Manlove,” according to the formal charge.

Manlove asserts that, based on her assessments of each case, “appropriate plea agreements were reached in those cases, and the victims were properly informed.”

The district attorney’s full response is 359 pages, with 42 of these written as point-by-point denials and admissions based on the charge’s assertions. The rest of the pages include documents and other evidence that are referred to in Manlove’s response.

The 23-page formal charge against Manlove was filed June 11 with the State Bar’s Board of Personal Responsibility by Special Bar Counsel W.W. Reeves. Based on what was found in the three investigations, Reeves asked the Board of Professional Responsibility to hold a formal disciplinary hearing into the allegations outlined within it, directly impose or recommend the Wyoming Supreme Court impose disciplinary measures against Manlove, and order Manlove to reimburse the State Bar for costs associated with the charge and hearing.

Brandi Robinson, clerk for the Board of Professional Responsibility, said Wednesday that she expected a decision to be made on a hearing date within two to three weeks.

Manlove refuted any claims by the State Bar that she dismissed an excessive amount of cases, asserting that any cases she dismissed were subject to her prosecutorial discretion and were signed off on by Laramie County judges.

Further, she said, she dismissed all of these cases “with prejudice,” meaning her office could recharge them in the future, if she chooses.

There is no evidence in the judges’ letter or the State Bar charge that “contain facts sufficient to second guess (Manlove’s) exercise of her considerable prosecutorial discretion,” she wrote.

She later asserted that the way the Office of Bar Counsel and the Laramie County judges try to support their opinions about how she responded to 2020 state budget constraints raises “significant separation of powers and Due Process concerns.”

Manlove also denied the claim that “most” of her office’s 800 circuit court case dismissals between October 2020 and February 2021 cited a Sept. 18 letter outlining her office’s limitations because of state budget cuts. Only 400 of these cases included the Sept. 18 letter, she said.

The State Bar charge alleges that it was not state budget cuts that caused caseload constraints, but Manlove’s conduct within her office that prompted many staff attorneys and other employees to resign.

In her response, Manlove pointed out that the Laramie County District Attorney’s office’s caseload had “increased significantly,” while the number of state-funded attorneys available to the office has decreased by two.

Manlove denied that resignations within her office “left too few employees to meet the obligations of the office,” saying that “all obligations of the Laramie County District Attorney’s Office have been reasonably met by its attorneys and support staff, and that if the citizens of Laramie County believe otherwise,” they can elect someone else.

She said she did not “encourage” law enforcement officers to “shoulder the burden of prosecuting all non-priority offenses,” and that based upon her knowledge of district courts and how things had been done in Laramie County “back in the day,” she believed law enforcement could appear in court and prosecute certain citations. In fact, Manlove wrote in her Sept. 18 letter that “local law enforcement will have to shoulder the burden of prosecuting all non-priority offenses, and prosecutors will no longer appear in court for those cases.”

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