In Re Ruffalo, 390 U.S. 544, 88 S. Ct. 1222, 20 L. Ed. 2d 117 (1968) was a federal disbarment case that was instituted after the attorney in question, Ruffalo, was disbarred by the Ohio Supreme Court. The United States Supreme Court set aside the federal disbarment because it had been based upon the state disbarment, and the Supreme Court found the state proceeding to be defective under due process. Ruffalo was charged with immoral and unethical conduct, i.e., hiring a railroad employee, Orlando, to solicit persons injured in railroad accidents to become clients of Ruffalo. Ruffalo and Orlando each testified that Orlando did not solicit clients but, rather, served as an accident investigator for Ruffalo. As a result of this testimony, the charges were amended to cite Ruffalo for the immoral and unethical conduct of hiring a railroad employee to investigate accidents that, on occasion, involved his own employer. Ruffalo was disbarred as a result of the additional charge. However, the Supreme Court concluded that it violated due process to lodge this additional charge, explaining as follows: 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.