In the 1992 case of James L. Martin v. District of Columbia Court of Appeals, et al., petitioner James L. Martin challenged his disbarment from practicing law in Washington D.C., arguing that it violated his due process rights under the Fifth Amendment and was inconsistent with principles of comity because he had not been disbarred in Maryland where the misconduct occurred. The U.S Supreme Court held that there was no constitutional violation as Martin received adequate notice and opportunity to be heard before being disbarred by the D.C court system, satisfying procedural due process requirements. Furthermore, they found no requirement for interstate recognition (comity) regarding attorney disciplinary actions; each jurisdiction has authority to regulate practice within its boundaries independently.

In the dissenting opinion for James L. Martin v. District of Columbia Court of Appeals, Justice Thomas argued that the majority's decision to uphold a rule requiring bar applicants in D.C. to have graduated from an accredited law school was not consistent with the Constitution's Privileges and Immunities Clause. He contended that this clause should protect citizens' right to pursue a livelihood by practicing law, regardless of where they received their education or training. Furthermore, he criticized the majority for deferring too much authority to professional organizations like American Bar Association (ABA) in determining who is qualified enough to practice law without considering whether such requirements are constitutionally valid or fair towards individuals who may have obtained legal knowledge through non-traditional means.