In the case of Withrow et al. v. Larkin, the U.S Supreme Court ruled on whether a state medical board could both investigate and adjudicate a disciplinary action against a doctor without violating due process rights under the Fourteenth Amendment. The court held that there was no constitutional violation in allowing an administrative body to perform investigative functions as well as adjudicative ones, provided that it did so fairly and impartially. Dr. Larkin had argued that his right to fair trial was violated because the same body which investigated him also decided his guilt or innocence; however, this argument was rejected by the court which stated that combining these two roles within one agency is not inherently unfair or unconstitutional.

In the dissenting opinion for Withrow v. Larkin, Justice William O. Douglas argued that due process was violated when a single administrative body both investigated and adjudicated the case against Dr. Larkin. He contended that combining investigative and adjudicative functions within one agency created an inherent bias, as those who conducted investigations would naturally be inclined to validate their own findings during adjudication. This, he believed, undermined the impartiality necessary in any trial or hearing situation - a fundamental requirement of due process under law. Furthermore, he expressed concern over potential abuses of power by such agencies if they were allowed to operate without checks on their authority from separate bodies or branches of government.