In O'Brien's Petition, 79 Conn. 46, 63 A. 777 (1906), the petitioner had sought a court hearing on his qualifications in the face of a recommendation from the Fairfield County bar that his application for admission be denied. The record reveals that, at the time, the rules of practice provided that the court could admit to practice only candidates who had received favorable recommendations from the admission committee of their county bars. On that basis, the trial court declined to hear evidence of the petitioner's character, ruling that it had no power to determine his qualifications in light of the county bar's negative recommendation.
In upholding the trial court's decision, our Supreme Court relied on two notions that no longer have legal or practical vitality. First, the court observed that a bar candidate has no liberty interest in practicing law, "nor did the refusal to admit the petitioner to an examination take from him, by authority of the State, either liberty or property. The inalienable right of every American citizen to follow any of the common industrial occupations of life does not extend to the pursuit of professions or vocations of such a nature as to require peculiar skill or supervision for the public welfare. . . . To disbar an attorney is to deprive him of what, within the meaning of our constitutions of government, may fairly be regarded as property. . . . But one who asks the privilege of admission to the bar is simply seeking to obtain a right of property which he has not got.
"The Superior Court, therefore, rightly declined to hear evidence as to questions the decision of which was entrusted to the State bar examining committee, and given to them only in case of those coming before them with the approval of the county bar." Id., at 55.
Finding that the applicant had no constitutionally protected right to practice law, the court concluded, therefore, that a bar applicant has no due process rights to a fair application process. Id.