77 263. Summarizing, the Commission considers that the disciplinary proceeding described above was itself a restriction of the alleged victim’s right to freedom of expression. As has been amply explained, that restriction does not meet the first requirement of the necessity test, i.e., a precise and clear legal provision. 264. Therefore, the Commission concludes that the State violated articles 9, 13(1) and 13(2) of the American Convention, read in conjunction with articles 1(1) and 2 thereof and to the detriment of Tirza Flores Lanza. d. Ramón Barrios 265. As the established facts show, the disciplinary process instituted against Judge Ramón Barrios did not end with his removal for exercising his right to freedom of expression. In effect, although a decision of the SCJ dismissed Judge Ramón Barrios from his office as Judge of the San Pedro Sula Sentencing Court for having expressed political opinions, the Judicial Career Council later reversed that decision and decided to guarantee the judge’s tenure in the Judicial Branch, as it reasoned that the speech for which he was sanctioned was “a personal legal opinion expressed in the context of a course on Constitutional Law” that he delivered, and as such was speech protected by the right to freedom of thought and expression recognized in the Constitution and international instruments. 266. The IACHR finds that the Judicial Career Council’s decision in Judge Barrios’ case met the requirements of international human rights law to the extent that it recognized that the judge’s right to express opinions when teaching was protected speech. However, the Commission notes that, as in the other cases, Judge Barrios had to endure a protracted disciplinary process against the backdrop of the coup d’état and based on legal provisions that were so ambiguous and broad that, as the Council’s own decision demonstrates, they are subject to differing and even contradictory discretionary interpretations. He had to defray the economic and personal expenses of his defense, in a disciplinary process marred by violations of due process and of his right of access to justice (supraparagraph 119168). Furthermore, while Judge Barrios’ process was still in progress, he continued to work as a Sentencing Court Judge, and received the corresponding remuneration. Strictly speaking he did not enjoy job security, since at any moment the Supreme Court decision that ordered his dismissal could take effect. 267. Based on the foregoing and on the legal arguments used to decide the petition as it pertained to Magistrate Tirza Flores Lanza (supra paragraphs 260-266), the Commission finds that, given the particular context of this case, the disciplinary process conducted against Judge Barrios took a disproportionate toll on his right to exercise free speech, in violation of articles 9, 13(1) and 13(2) of the American Convention, in relation to articles 1(1) and 2 thereof. 3. Use of disciplinary proceedings as an indirect means of restriction or limitation 268. There are multiple ways of unlawfully limiting freedom of expression, from the most radical form of suppression in the form of prior censorship, to less obvious, more subtle and sophisticated means. Article 13(3) of the American Convention makes specific reference to this indirect method “to impede the communication and circulation of ideas and opinions.” In effect, that article provides that: