The New York State Bar Association is examining whether to remove President Donald Trump’s personal attorney Rudy Giuliani from its membership rolls after he called for “trial by combat” at a rally for President Donald Trump just before crowds stormed the U.S. Capitol, association president Scott Karson announced Monday.

In a news release, the bar association said it has received hundreds of complaints in recent months about Giuliani’s efforts to cast doubt on the outcome of the 2020 presidential election and “overturn its legitimate results.”