Question juridique clé
Whether the referral to the cantonal bar commission was an appealable decision
Solution extraite
The referral was only a first step toward possible disciplinary proceedings and did not itself determine a legal relationship; it was therefore not a decision that could be challenged by constitutional complaint or administrative law appeal.
Motifs extraits
A referral for possible supervisory action does not authoritatively regulate the individual's legal position. Even as a possible interim decision in later disciplinary proceedings, it caused no irreparable harm because the lawyer could fully defend himself before the bar commission and challenge any sanction later.