In State ex rel. Smirnoff v. Greene, 84 Ohio St.3d 165, 1998 Ohio 526, 702 N.E.2d 423, a physician was indicted on multiple counts of drug trafficking and corrupting another individual with drugs. As a condition of the pre-trial bail, the trial judge ordered that the physician could not prescribe or administer any "dangerous" drug. Asserting that the condition deprived him of the ability to practice medicine, the physician brought a habeas corpus action to contest the legality of the trial judge's order. The court of appeals granted the writ and amended the disputed condition to allow the physician to prescribe certain drugs to his patients. However, on appeal, the Supreme Court of Ohio specifically held that the writ should have been denied. In the first part of its analysis, the Smirnoff court indicated that under Ohio law, a habeas corpus action cannot generally be employed as a means of challenging a condition of bail. As to this point, the opinion noted that, even in "excessive bail" cases, a criminal defendant must be subject to actual physical confinement before the writ will issue. Id. at 167-168. In the second portion of its discussion, the Smirnoff court further indicated that, unlike Ohio precedent, federal case law has concluded that the propriety of a bail condition can be raised as part of a habeas corpus proceeding. However, the court then emphasized that, even under the federal precedent, a bail condition will only be invalidated under the rarest of circumstances: "'Since habeas corpus is an extraordinary remedy whose operation is to a large extent uninhibited by traditional rules of finality its use has been limited to cases of special urgency, leaving more conventional remedies for cases in which the restraints on liberty are neither severe nor immediate.' Hensley v. Mun. Court, San Jose Milpitas Judicial Dist. Santa Clara Cty. (1973), 411 U.S. 345, 351, 93 S. Ct. 1571, 36 L. Ed. 2d 294." Id. at 168. Applying the foregoing standard to the disputed condition in Smirnoff, the Supreme Court of Ohio ultimately stated that a writ of habeas corpus would not lie even under federal law because the restriction on the physician's right to prescribe drugs was not sufficiently harsh to warrant any relief: "This condition did not limit the physician's freedom of movement or otherwise represent a restriction on his liberty severe enough to require the writ." Id. at 169.