Lest anyone think the temporary suspension of former Mayor Rudy Giuliani was a violation of his constitutional rights to due process or free speech, the facts and law are to the contrary. Since the 1986 landmark New York Court of Appeals case, Matter of Padilla, 67 N.Y.2d 440 (1986), later codified in the New York Rules for Attorney Disciplinary Matters, 22 NYCRR §1240.9,[1] lawyers here (and in most U.S. jurisdictions) have been subject to immediate, temporary suspension, without formal charges and an evidentiary hearing, if there is sufficient proof, ab initio, that their misconduct constitutes an immediate danger to the bar and the public. While it is certainly true that many of these cases involved stealing client funds, that certainly does not alter the fact that courts can and will temporarily suspend lawyers for a variety of misdeeds so long as the misconduct warrants such treatment. See, e.g., Matter of Truong, 2 A.D.3d 27 (1st Dep't 2003) (uncontested evidence that attorney offered a forged lease into evidence, gave false testimony in support of that document, and initiated frivolous litigation, temporarily suspended on the ground that his behavior constituted an immediate threat to the public interest). The burden is on the petitioning Attorney Grievance Committee (AGC), but notably—and in consideration of "due process" concerns—the respondent lawyer always has an absolute right to be heard following receipt of a petition and before imposition of discipline. The decision of the Appellate Division interimly suspending Giuliani makes clear that he was given that opportunity and did, in fact, submit a response. Matter of Giuliani, 2021 WL 2583536 (1st Dep't, June 24, 2021) (citing Giuliani's affidavit in opposition to the AGC's petition).