A Washington D.C.-based attorney review panel concluded Friday former New York Mayor Rudy Giuliani should be disbarred in the city due to his efforts in perpetrating false 2020 election claims on behalf of former President Donald Trump.

The three-member disciplinary counsel said its review "proved by clear and convincing evidence" that Giuliani violated Pennsylvania law, and concluded he should be disbarred.

It said his "frivolous" lawsuit seeking to change the 2020 election results "when he had no factual basis, and consequently no legitimate legal grounds, to do so" should mean he forfeits his right to practice law.

"Mr. Giuliani’s effort to undermine the integrity of the 2020 presidential election has helped destabilize our democracy," the panel said. "His malicious and meritless claims have done lasting damage and are antagonistic to the oath to 'support the Constitution of the United States of America' that he swore when he was admitted to the Bar."

SEE MORE: Trump lawyer Rudy Giuliani interviewed in Jan. 6 investigation

Giuliani has been a member of the D.C. bar since 1976 but has been inactive since 2002. Last year, its disciplinary arm filed the ethics charge against him for the false election claims.

A New York court has already suspended Giuliani from practicing law in New York over his false election claims in support of Trump. And two other lawyers are facing disbarment in other states for the same reason.

Giuliani and other Trump lawyers have repeatedly made unfounded claims of election fraud, including in a 2020 federal Pennsylvania court case that sought to overturn the state's election results. In the case, Giuliani supported a claim that a large number of mail-in ballots should be invalidated over fraud, but a federal judge dismissed the case, saying it lacked "compelling legal arguments and factual proof of rampant corruption."

The panel Friday echoed the judge's sentiment, saying Giuliani "did not offer any evidence that fraudulent mail-in votes were actually cast or counted."

It also responded to Giuliani's claim that his knowledge of the events was based on what other Trump allies said.

"Mr. Giuliani’s argument that he did not have time fully to investigate his case before filing it is singularly unimpressive. He sought to upend the presidential election but never had evidence to support that effort," the panel said.

Now the D.C. panel's review will go to the Court of Appeals for a final decision.

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Dominion Voting Systems' $1.6 billion defamation lawsuit against Fox News is entering a new phase. Lawyers at the Superior Court in Wilmington, Delaware, are choosing members of the jury ahead of the trial's opening statements Monday.

"The jury will be asked to decide whether Fox betrayed its responsibility as a journalist organization," said NYU law professor Burt Neuborne.

Judge Eric Davis has already ruled that Fox's reporting on air about the company was not factual. Now, Dominion's lawyers must convince a jury that the coverage was defamation. 

Neuborne says the Supreme Court — in a previous ruling — established a standard of "actual malice," created in the 1964 case New York Times v. Sullivan. 

"What they still have to do is persuade the jury that Fox, or any of the other defendants in the case, acted with such reckless disregard for the truth that they either knew they were lying, or were such bad journalists that they shouldn't even be accorded the kinds of First Amendment protection that we give to ordinary journalists," Neuborne said.

SEE MORE: Fox libel defense at odds with top GOP presidential foes

After former President Donald Trump lost the 2020 election, the most prominent of Fox News hosts, including Sean Hannity, Tucker Carlson and Maria Bartiromo, as well as frequent guests, like Rudy Giuliani and Sidney Powell, echoed Trump's conspiracy theories relating to Dominion, including claims that votes were changed or deleted in favor of Joe Biden, and that Dominion rigged elections for a Venezuelan dictator who died in 2013 — all of which are false. 

The Canadian-based company provides software to manage elections, as well as voting machines and tabulators. In the 2020 election, it provided services to more than half of states in the U.S., including states in which Republicans alleged unfounded fraud claims.

Fox refused to retract its statements despite Dominion calling for them to do so. 

SEE MORE: Murdoch acknowledges some Fox hosts 'endorsed' false election claims

Fox contends the allegations against Dominion were at the time newsworthy and are protected by the first amendment. But the release of text messages from some of the most prominent on-air talent cast doubt on just how earnest those concerns really were.

"That First Amendment protection is defeated if the journalist is consciously lying, or if the journalist is functioning so badly, with such lack of regard for the truth, that the journalist can be characterized as being reckless about the truth," Neuborne said.

Judge Davis sanctioned Fox News Wednesday afternoon, after recordings were handed over by a former Fox producer of discussions she had with Giuliani and Powell. Dominion's lawyers were not given them during the discovery phase of the trial. Judge Davis says the company will be able to conduct another deposition. The producer — Abby Grossberg — contends Fox pressured her to give false testimony in the case. 

Fox's biggest stars and executives could take the stand during the trial, and Dominion is pushing for others, including Murdoch and even board member and former House Speaker Paul Ryan. At stake is the $1.6 billion Dominion is seeking in compensation.