The Supreme Court of Tennessee recently confronted the issue of whether the state’s lawyer discipline system violated due process.  See Long v. Board of Professional Responsibility,  “Long contended that Rule 9 is unconstitutional and violates his due process rights because Rule 9 combines investigative, enforcement, and adjudicative authority in the same agency; creates a financial incentive for the Board to pursue formal disciplinary proceedings; and gives rise to an institutional bias in favor of finding guilt and imposing discipline.”  The court said that “[b]ecause the investigatory/enforcement responsibilities and the adjudicative responsibilities are functionally separate within the Board, Rule 9 does …