In the 1973 case of Taylor v. Hayes, Judge, the U.S. Supreme Court ruled in favor of a lawyer who had been held in contempt by a Kentucky judge during a murder trial and subsequently disbarred without being given an opportunity to defend himself against the charges. The court found that this violated his due process rights under the Fourteenth Amendment. Justice William O. Douglas wrote for the majority stating that while judges have broad discretion to maintain order in their courts, they must also respect attorneys' constitutional rights including due process when issuing contempt citations or disbarring them from practicing law within their jurisdiction.

In the dissenting opinion for Taylor v. Hayes, Justice Douglas argued that the majority's decision to uphold a contempt citation against an attorney was misguided and could potentially undermine the independence of legal counsel in court proceedings. He contended that while attorneys should certainly be held accountable for their behavior in court, they must also have some leeway to vigorously defend their clients without fear of reprisal from judges who may not appreciate or agree with their tactics or arguments. In this particular case, he believed that Judge Hayes had overstepped his authority by holding Taylor in contempt without providing him with due process rights such as notice and opportunity to be heard before being punished. Furthermore, he expressed concern about potential abuse of power by judges who might use contempt citations as a tool to silence or intimidate lawyers whom they dislike or disagree with.