In In Re Ruffalo, 390 U.S. 544 (1968), an attorney was charged with twelve counts of misconduct. During his testimony at his disciplinary hearing, the attorney made a statement resulting in the Board of Commissioners on Grievances and Discipline adding a thirteenth charge. The charges against the attorney were amended to add a count based on a defense that the attorney had presented during his testimony. See 390 U.S. at 550. The Supreme Court held that "this absence of fair notice as to the reach of the grievance procedure and the precise nature of the charges deprived petitioner of procedural due process." Id. at 552. Ruffalo, an Ohio lawyer who handled a number of Federal Employer's Liability Act ("FELA") cases, was charged by the bar association with a number of violations of the disciplinary rules including his use of a part-time employee named Orlando to solicit FELA clients. See 390 U.S. at 546. Ruffalo and Orlando both testified that Orlando was employed only to investigate the cases and did not solicit clients on behalf of Ruffalo. See id. During the course of the proceeding, however, it was revealed that Orlando was employed by one of the railroads against which Ruffalo had brought some of his cases. See id. The bar association thereafter added an additional charge against Ruffalo in the midst of the hearing, that Ruffalo's employment of Orlando to investigate against his employer was "deceptive in nature and was morally and legally wrong." Id. at 547. Ruffalo was given a continuance to respond to the new charge. See id. In disbarring Ruffalo, the Ohio Supreme Court concluded that "one who believes that it is proper to employ and pay another to work against the interests of his regular employer is not qualified to be a member of the Ohio bar." Mahoning County Bar Ass'n v. Ruffalo, 176 Ohio St. 263, 199 N.E.2d 396, 401 (Ohio 1964). The United States Supreme Court held that the lack of notice to the attorney as to "the reach of the grievance procedure and the precise nature of the charges" deprived the attorney of procedural due process. Id. at 552. The Court stated: These are adversary proceedings of a quasi-criminal nature. The charge must be known before the proceedings commence. They become a trap when, after they are underway, the charges are amended on the basis of testimony of the accused. He can then be given no opportunity to expunge the earlier statements and start afresh. Id. at 551.