Daniel Urrutia Laubreaux from violation of the right to defense, as already established, nor did it properly balance the alleged affects of his academic paper against the right to freedom of expression as enshrined in the Constitution and the Convention. 74. Based on this, the Commission concludes that the Chilean State is responsible for the violation of the rights enshrined in articles 8(1) and 25(1) of the American Convention, in conjunction with Article 1(1) of the same instrument, to the detriment of Daniel Urrutia Laubreaux. 4. Principle of legality45 75. The principle of legality recognized in Article 9 of the Convention governs the actions of State bodies when they move to exercise their power to punish.46 The principle is applicable to disciplinary processes that are “an expression of the punitive power of the State” because illegal conduct in these processes can harm or affect the rights of individuals.47 76. The IACHR has stated that disciplinary procedures against justice operators must include clear rules on the grounds and procedure for removing judges from office. Absence thereof, in addition to fueling doubts about the independence of the judiciary, can lead to arbitrary abuses of power, with direct repercussions for the rights of due process.48 77. Regarding this, the law should provide detailed specifications of the infractions that could lead to the imposition of disciplinary measures, including the gravity of the infraction and the type of disciplinary measure to be applied if applicable. The European Court has found in the case of Maestri v. Italy that the principle of legality not only requires the disciplinary grounds to have a basis in domestic law, but also that the law establishing those grounds be accessible to the people to whom it applies. It also must be sufficiently precise so as to make the circumstances and consequences of actions to which disciplinary measures apply foreseeable. 78. In the context of the independence of judges, the Office of the Rapporteur has indicated that, “vague or ambiguous legal provisions that grant, through this channel, very broad discretionary powers to the authorities are incompatible with the American Convention because they can support potentially arbitrary acts that are tantamount to prior censorship or that establish disproportionate liabilities for the expression of protected speech.”49 79. In the case of López Lone, the Inter-American Court found that “it is impossible to codify all assumptions in disciplinary matters, so that ultimately, there must always be a relatively open clause concerning professional duties. However, in these assumptions and when open or indeterminate disciplinary offenses are used, it is fundamental to provide a statement of reasons when applying them, because it is incumbent on the disciplinary court to interpret these norms respecting the principle of legality and observing the greatest rigor when verifying the existence of punishable conduct.”50 45Article 9 of the American Convention establishes that “No one shall be convicted of any act or omission that did not constitute a criminal offense, under the applicable law, at the time it was committed. A heavier penalty shall not be imposed than the one that was applicable at the time the criminal offense was committed. If subsequent to the commission of the offense the law provides for the imposition of a lighter punishment, the guilty person shall benefit therefrom. 46 IACHR, Criminalization of the Work of Human Rights Defenders, OEA/Ser.L/V/Doc.49/15, December 31, 2015, para. 253. 47 Inter-American Court, Case of López Lone et al. v. Honduras. Preliminary Objections, Merits, Reparations and Costs. Judgment of October 05, 2015. Series C No. 302, para. 257 and Case of Maldonado Ordoñez v. Guatemala. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 3, 2016. Series C No. 311, para. 89. Inter-American Court. Case of Baena Ricardo et al. v. Panama. Merits, Reparations, and Costs. Judgment dated February 2, 2001. Series C No. 72, paras. 106 and 108. 48 IACHR, Guarantees for the Independence of Justice Operators. Towards strengthening access to justice and the rule of law in the Americas, OEA/ser.L/V/II.Doc.44, December 5, 2013, para. 206 and 207. 49 IACHR, Guarantees for the Independence of Justice Operators. Towards strengthening access to justice and the rule of law in the Americas, OEA/ser.L/V/II.Doc.44, December 5, 2013, para. 209. 50 Inter-American Court, Case of López Lone et al. v. Honduras. Preliminary Objections, Merits, Reparations and Costs. Judgment of October 05, 2015. Series C No. 302, para. 271. 13