102. In addition, Article 8(2) of the Convention establishes the minimum guarantees that must be guaranteed by the State to ensure due process of law. 91 This Court has established that the guarantees indicated in Article 8(2) of the Convention are not exclusive to criminal proceedings, and may also be applicable in proceedings involving sanctions. 92 That said, in each case it is necessary to determine the minimum guarantees applicable to a specific proceeding involving non-criminal sanctions according to its nature and scope.93 103. Based on the sanctioning nature of the disciplinary proceedings held against Mr. Urrutia Laubreaux, in which a decision was taken that affected the presumed victim’s rights, the Court considers that the procedural guarantees established in Article 8 of the American Convention form part of the list of minimum guarantees that should be respected to take a decision that is not arbitrary and that is adapted to due process. 104. Additionally, in cases involving disciplinary proceedings against judges, the Court’s case law has indicated that the scope of the judicial guarantees and of real judicial protection for judges must be examined in relation to the standards for judicial independence. In the case of Reverón Trujillo v. Venezuela, the Court indicated that judges, contrary to other public officials, have specific guarantees owing to the necessary independence of the Judiciary, which the Court has understood as “essential for the exercise of the judicial function.”94 105. The State must ensure the autonomous exercise of the judicial function as regards both its institutional aspect – that is, in relation to the Judiciary as a system – and its individual aspect – that is, in relation to the person of the specific judge.95 The following guarantees are derived from judicial independence: an adequate selection process, 96 guaranteed tenure,97 and the guarantee against external pressures.98 106. Regarding the guarantee against external pressures, the Court has indicated that the State must refrain from undue interference in the Judiciary or with its members, and take measures to avoid such interference being committed by persons or organs outside the Cf. Case of Baena Ricardo v. Panama. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 137, and Case of Petro Urrego v. Colombia. Preliminary objections, merits, reparations and costs, supra, para. 120. 91 Cf. Case of Maldonado Ordóñez v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of May 3, 2016. Series C No. 311, para. 75. 92 Case of Maldonado Ordóñez v. Guatemala. Preliminary objection, merits, reparations and costs, supra, para. 75, and Case of Rosadio Villavicencio v. Peru. Preliminary objections, merits, reparations and costs, supra, para. 125. 93 Cf. Case of Reverón Trujillo v. Venezuela. Preliminary objection, merits, reparations and costs. Judgment of June 30, 2009. Series C No. 197, para. 67, and Case of Rico v. Argentina. Preliminary objection and merits, supra, para. 52. 94 Cf. Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela. Preliminary objection, merits, reparations and costs. Judgment of August 5, 2008, para. 55, and Case of Rico v. Argentina. Preliminary objection and merits, supra, para. 53. 95 Cf. Case of the Constitutional Court v. Peru. Merits, reparations and costs. Judgment of January 31, 2001, para. 75, and Case of Colindres Schonenberg v. El Salvador. Merits, reparations and costs, supra, para. 68. See also: ECHR, Case of Campbell and Fell v. The United Kingdom, Judgment of June 28, 1984, para. 78; Case of Langborger v. Sweden, Judgment of January 22, 1989, para. 32, and Principle 10 of the United Nations Basic Principles on the Independence of the Judiciary, adopted by the Seventh United Nations Congress on the Prevention of Crime and the Treatment of Offenders held at Milan from 26 August to 6 September 1985 and endorsed by General Assembly resolutions 40/32 of November 29, 1985, and 40/146 of December 13, 1985. 96 Cf. Case of the Constitutional Court v. Peru. Merits, reparations and costs, supra, para. 75, and Case of Colindres Schonenberg v. El Salvador. Merits, reparations and costs, supra, para. 68. See also Principle 12 of the United Nations Basic Principles. 97 Cf. Case of the Constitutional Court v. Peru. Merits, reparations and costs, supra, para. 75, and Case of Colindres Schonenberg v. El Salvador. Merits, reparations and costs, supra, para. 68. See also, Principles 2 and 4 of the United Nations Basic Principles. 98 27