In 1983, Snyder submitted an application for CJA compensation for a case he had handled before Judge Bruce Van Sickle in the District Court.

Because the request exceeded $1,000, it was subject to review by the Chief Judge of the Eighth Circuit Court of Appeals, Donald P. Lay.

Snyder closed his letter by stating: "Further, I am extremely disgusted by the treatment of us by the Eighth Circuit in this case, and you are instructed to remove my name from the list of attorneys who will accept criminal indigent defense work.

Lay, however, opined that Snyder's letter was "totally disrespectful to the federal courts and to the judicial system.

Judge Van Sickle responded that Snyder viewed the letter as "an expression of an honest opinion, and an exercise of his right of freedom of speech."

Judge Lay then issued an order to show cause directing Snyder to explain why he should not be suspended from practicing law in the Eighth Circuit.

The stated basis for the order to show cause was Snyder's statement that he would no longer accept case assignments under the CJA.

Because the case could be resolved on non-constitutional grounds, Burger wrote, the Court need not address Snyder's arguments under the First Amendment or the Due Process Clause.