63. The IACHR also highlights that disciplinary processes conducted against operators of justice should be compatible with the principle of judicial independence. The bodies of the inter-American system have interpreted the principle of judicial independence to include the following guarantees: an adequate appointment process, tenure, and protection from external pressures.33 2. Right to prior notification in detail of charges and adequate time and means for defense34 64. The Commission recalls that the right to defense means ensuring that individuals subjected to a process, including an administrative process, can defend their interests or rights effectively and on an equal footing, being fully informed of the accusations formulated against them.35 Specifically with regard to procedures for disciplining judges, the Inter-American Court has followed the provisions of the Basic Principles by indicating that the authority in charge of the disciplinary process should conduct itself in compliance with established procedures and permit exercise of the right to defense.36 The Court has found that the right to defense must necessarily be exercised from the outset of the identification of an individual as a potential perpetrator of or participant in a punishable act, and its exercise only concludes once the process is complete.37 In keeping with what was indicated previously, this is equally applicable to disciplinary processes that can resulting in a sanction. 65. In this case, the IACHR observes that the alleged victim was never notified that he was subject to a disciplinary procedure. In this regard, the record shows that on January 12, 2005, the La Serena Appellate Court asked the alleged victim to report his motive for sending a copy of his academic paper to the Supreme Court, but did not tell him its request was part of a disciplinary process, nor the alleged infraction for which he was accused. Without knowledge of this, on January 17, 2005, the alleged victim sent the information requested. On March 31, 2005, the La Serena Appellate Court applied the disciplinary measure of written censure to him, and on May 6, 2005, the Supreme Court confirmed this decision, although it changed the sanction to private admonishment. The Commission additionally highlights that pursuant to Article 536 of the Organic Code of Tribunals, a preliminary hearing should have been held to present his defense. This also did not take place in this case. 66. It can be concluded from this that the alleged victim was not informed of the disciplinary process brought against him, the reasons for it, or the rules he may have violated with his conduct. This affected not only his right to prior notification in detail of the charges, but also his right to prepare an adequate defense, as on one hand, he did not formulate his response as a form of defense, and on the other, the process did not comply with the legally established requirement of a hearing. 67. Based on these considerations, the IACHR concludes that the State violated articles 8(2)(b) and 8(2)(c) of the American Convention, in conjunction with Article 1(1) of the same instrument, to the detriment of Daniel Urrutia Laubreaux. 33IACHR, Report on Guarantees for the Independence of Justice Operators. Towards strengthening access to justice and the rule of law in the Americas, December 5, 2013, paras. 56, 109 and 184, Inter-American Court. Case of López Lone et al. v. Honduras. Preliminary Objections, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 191. 34 The pertinent part of Article 8(2) reads as follows: 2. Every person accused of a criminal offense has the right to be presumed innocent so long as his guilt has not been proven according to law. During the proceedings, every person is entitled, with full equality, to the following minimum guarantees: b. prior notification in detail to the accused of the charges against him; c. adequate time and means for the preparation of his defense; 35 Inter-American Court. Juridical Condition and Rights of Undocumented Migrants. Advisory Opinion OC-18/03 of September 17, 2003. Series A No. 18, para. 117. 36 IACHR Report No. 103/13, Case 12,816, Merits Report, Adan Guillermo López Lone et al., Honduras, para. 143. 37 Inter-American Court, Case of Barreto Leiva v. Venezuela. Merits, Reparations, and Costs. Judgment of November 17, 2009. Series C No. 206. Para. 29. Citing mutatis mutandis the Inter-American Court, Case of Suárez Rosero v. Ecuador. Judgment of November 12, 1997. Series C No. 35, para. 71; and Case of Heliodoro Portugal v. Panama. Preliminary Objections, Merits, Reparations and Costs. Judgment dated August 12, 2008. Series C No. 186, para. 148. 11