that disciplinary grounds should be established in the State’s legal framework, in keeping with the standards described above, the justification for a ruling should disclose “the facts, reasons, and provisions the authority relied on in reaching its decision.”61 In that sense, the justification for the punitive decision is what explains how the facts that were the basis of the proceeding align with or fall within the scope of the grounds invoked. On this point, in De la Cruz Flores v. Perú, the Court stressed the need that in all punitive decisions there be a link between the conduct of which the person is accused and the provision on which the decision is based.62 86. In terms of the applicable penalty, the “principle of maximum severity” of the punishment of dismissal of a justice operator implies that it is only appropriate for “clearly punishable” conduct, “based on the most serious grounds of misconduct or incompetence.”63 Thus, for example, the protection of judicial independence requires that the dismissal of judges be considered the last resort in judicial disciplinary matters. 64 In its report “Guarantees for the Independence of Justice Operators,” the IACHR indicated the following: “Under international law, the penalty of suspension or removal must be applied only in the case of the most serious misconduct. As the Council of Europe recommended with respect to disciplinary offences, the disciplinary measures should become stricter as the seriousness of the offence increases, and can include removal of cases from a judge, assigning the judge other tasks, economic sanctions and suspension.”65 Moreover, the Court has indicated that the tenure of justice operators implies that dismissal is due to very serious conduct, while other sanctions may be used in the case of negligence or lack of capacity.66 87. With respect to the right to freedom of expression, inter-American case law has held that the entitlement to this right enshrined in the American Convention cannot be confined to a specific profession or group of persons, or to the realm of freedom of the press. This broad perspective includes, of course, prosecutors, who do not forfeit their basic rights upon taking office; instead they enjoy the same freedom of expression that every other person enjoys.67 88. Inter-American case law has also established that the exercise of this right by public officials has certain connotations and specific characteristics.68 The Court has maintained, for example, that the critical democratic role of freedom of expression demands that, in certain cases, public officials make statements on matters of public interest in the performance of their legal duties, especially concerning investigations into acts of corruption. In other words, under certain circumstances, the exercise of their freedom of expression is not just a right but a duty.69 89. Likewise, since the adoption of Advisory Opinion OC-5/85 and repeatedly in case law, the Inter-American Court has indicated that freedom of expression, particularly in matters of public interest, “is a cornerstone upon which the very existence of a democratic society rests.” The Court has stated, “Without an effective guarantee IACHR, Report No. 103/13, Case 12.816, Report on the Merits, Adán Guillermo Lopez Lone et al., Honduras, OEA/Ser.L/V/II.149, Doc. 27, November 5, 2013, para. 145. 62 I/A Court H.R., Case of De la Cruz Flores v. Peru, Merits, Reparations, and Costs, Judgment of November 18, 2004, Series C. No. 115, para. 84. 63 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. 259. 64 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. 259; IACHR, Report No. 38/16, Case 12.768, Merits, Omar Francisco Canales Ciliezar, Honduras, August 31, 2016, para. 71 and ff. See also IACHR, Guarantees for the Independence of Justice Operators: Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, para. 211. In that report, the IACHR held that “laws that establish administrative disciplinary measures such as dismissal must be subjected to the strictest test of legality. Such laws not only provide for extremely serious penalties and curtail the exercise of rights, but also create an exception to the principle of judicial stability and can compromise the principles of judicial independence and autonomy.” 65 IACHR, Guarantees for the Independence of Justice Operators: Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, para. 217. 66 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. 199. 67 IACHR, Report No. 103/13, Case 12.816, Report on the Merits, Adán Guillermo López Lone et al., Honduras, OEA/Ser.L/V/II.149, Doc. 27, November 5, 2013, para. 201; IACHR, Report No. 21/18, Case 12.955, Merits, Daniel Urrutia Laubreaux, Chile, February 24, 2018, para. 84. 68 IACHR, Annual Report 2009, Report of the Special Rapporteur for Freedom of Expression, OEA/Ser.L/V/II Doc. 51, December 30, 2009, Chapter III, para. 202 and ff. 69 I/A Court H.R., Case of Ríos et al. v. Venezuela, Preliminary Objections, Merits, Reparations, and Costs, Judgment of January 28, 2009, Series C No. 194, para. 139; Case of Perozo et al. v. Venezuela. Preliminary Objections, Merits, Reparations, and Costs, Judgment of January 28, 2009, Serie C No. 195, para. 151. 61 17