that Justice Carlos Fernández used the three hours provided while Justice Bonifacio Ríos extended his defense to five and a half hours. 62. The Commission notes that, quite aside from the unconventional nature of the ad hoc regulation regarding the exercise of the right of defense, which was analyzed in the previous section, the IACHR does not have sufficient evidence to determine how the time frame provided impinged on the right to a hearing and the right of defense.43 While the 48-hour period may be seen as excessively short, in light of the State’s argument the IACHR does not have evidence to determine that the time to prepare and present a defense, as carried out in practice, violated the Convention. Based on the foregoing considerations, the Commission concludes that the Paraguayan State did not violate the right to a hearing and the right of defense to the detriment of Bonifacio Ríos Ávalos and Carlos Fernández Gadea. 5. The principle of judicial independence, the principle of freedom from ex post facto laws, and the right to have well-reasoned decisions 63. The Commission calls to mind that disciplinary proceedings against justice operators should be carried out in a way that is compatible with the principle of judicial independence. Based on that principle, it follows that States should provide reinforced guarantees to judges to ensure their independence. 44 The bodies of the inter-American system have interpreted the principle of judicial independence in the sense of incorporating the following guarantees: an adequate appointment process, tenure in the position, and the guarantee against external pressures.45 Specifically, as pertains to the case at hand, the Court has indicated with respect to the guarantee of tenure, that “the scope of judicial independence results in the subjective right of judges to be dismissed exclusively for the reasons permitted, either by a proceeding that complies with judicial guarantees or because their mandate has terminated.”46 When a judge’s tenure is arbitrarily impaired, “the right to judicial independence recognized in Article 8(1) of the American Convention is violated.”47 64. For its part, the principle of legality (freedom from ex post facto laws) governs the actions of State bodies when the exercise of the State’s punitive powers are involved, and it is applicable to disciplinary proceedings, which are an expression of that power as they imply an impairment or alteration of a person’s rights as a consequence of a wrongful conduct.48 The IACHR has indicated that in the context of disciplinary proceedings against justice operators, there must be clear rules concerning the grounds and procedure for removing judges from office. The absence of such rules, 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 and of freedom from ex post facto laws.49 Specifically, the law must give detailed guidance on the infractions by judges that can trigger disciplinary measures, including the gravity of the infraction and the kind of disciplinary measure to be applied in such a case.50 The Commission has stressed that “under international law the grounds for disciplinary investigations and sanctions imposed on a judge should never be a legal opinion or judgment he or she wrote in a decision.”51 See I/A Court. H.R., Case of López Mendoza v. Venezuela. Merits, Reparations, and Costs. Judgment of September 1, 2011. Series C No. 233, para. 121. 44 I/A Court. H.R., Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of August 5, 2008. Series C No. 182, para. 147. 45 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, paras. 56, 109, and 184; I/A Court. H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 191. 46 I/A Court. H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 192. 47 I/A Court. H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 192. 48 I/A Court. H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 257. 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, paras. 206 and 207. 50 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. 208. 51 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. 216. 43 16