Following his term as governor, Combs returned to his legal practice.
He was a charter member and chairman of the Eastern Kentucky Historical Society and a trustee at Campbellsville College.
In 1963, he was awarded the Joseph P. Kennedy International Award for "outstanding contributions and leadership in the field of mental retardations."
He was named Kentucky's outstanding attorney in 1964, and in the spring of that year, he served as a visiting professor in the Political Science Department at the University of Massachusetts.
In 1965, he was inducted into the University of Kentucky's Hall of Distinguished Alumni.

In August 1964, Combs declined a nomination to the bench of the United States District Court for the Western District of Kentucky.
During the administration of Combs' successor, Ned Breathitt, Republicans gained strength within the state behind the leadership of Louie Nunn, Marlow Cook, and William O. Cowger.
The Republican rise, coupled with Democratic factionalism, prompted many prominent state Democrats to approach Combs about seeking another term as governor.
Combs wavered on whether to seek the Democratic nomination until October 1966, when he publicly declared his support for Henry Ward.
In a later interview with historian George W. Robinson, Combs recounted that he "would have run at that time except for a personal family situation".
Ward handily defeated his primary opponents, Happy Chandler and Harry Lee Waterfield, but lost in the general election to Louie Nunn.

On January 16, 1967, President Lyndon Johnson nominated Combs to the United States Court of Appeals for the Sixth Circuit, replacing the deceased Shackelford Miller Jr., and the Senate confirmed the nomination on April 5, 1967, and Combs received his commission the same day.
Because of the rules of the federal judiciary, Combs had to liquidate his business and banking assets and severely restrict contact with many of his political acquaintances to avoid potential conflicts of interest with cases he might adjudicate on the Court of Appeals.
He expressed frustration that the cases that came before the court were frequently appealed to the Supreme Court, which often gave little weight to the opinions rendered by the Court of Appeals.
Consequently, he resigned from the court on June 5, 1970, and joined the Louisville law firm of Tarrant, Combs, and Bullitt (later Wyatt, Tarrant & Combs).

With the end of Governor Nunn's term approaching, a rivalry for leadership of the state Democratic party developed between Lieutenant Governor Wendell H. Ford, who had served as Combs' chief administrative assistant during his gubernatorial term, and Julian M. Carroll, speaker of the state House of Representatives.
As soon as Combs resigned from the Court of Appeals, Democratic leaders began asking him to seek the party's gubernatorial nomination in 1971, uniting the party behind him rather than splintering it between Ford and Carroll.
In June 1970, Carroll announced his intent to run for lieutenant governor, indicating that he would like to serve under Combs as governor.
While Combs considered whether or not to seek the nomination, Ford declared his candidacy.
Days later, Combs also entered the race.

Combs and Ford advocated similar platforms, but Combs encouraged the state's teachers to become more politically active, negotiating higher salaries and better benefits for themselves, while Ford was critical of educators becoming involved in politics and only advocated more spending on education if the state could afford it.
In his oral history of Combs, Robinson noted that Ford, thirteen years Combs' junior, "came across better on television" and that many voters in the state felt that Combs must have ulterior motives in leaving a judgeship that paid a salary of $42,500 for the governorship, which paid only $30,000 annually.
Catholics were also upset that Combs had married his second wife, Helen Clark Rechtin, just forty-three days after his divorce from Mabel Hall was finalized on July 18, 1969. (
Combs and Hall had been separated for five years prior to finalizing
Following his term as governor, Combs returned to his legal practice. He was a charter member and chairman of the Eastern Kentucky Historical Society and a trustee at Campbellsville College. In 1963, he was awarded the Joseph P. Kennedy International Award for "outstanding contributions and leadership in the field of mental retardations." He was named Kentucky's outstanding attorney in 1964, and in the spring of that year, he served as a visiting professor in the Political Science Department at the University of Massachusetts. In 1965, he was inducted into the University of Kentucky's Hall of Distinguished Alumni.
In August 1964, Combs declined a nomination to the bench of the United States District Court for the Western District of Kentucky. During the administration of Combs' successor, Ned Breathitt, Republicans gained strength within the state behind the leadership of Louie Nunn, Marlow Cook, and William O. Cowger. The Republican rise, coupled with Democratic factionalism, prompted many prominent state Democrats to approach Combs about seeking another term as governor. Combs wavered on whether to seek the Democratic nomination until October 1966, when he publicly declared his support for Henry Ward. In a later interview with historian George W. Robinson, Combs recounted that he "would have run at that time except for a personal family situation". Ward handily defeated his primary opponents, Happy Chandler and Harry Lee Waterfield, but lost in the general election to Louie Nunn.
On January 16, 1967, President Lyndon Johnson nominated Combs to the United States Court of Appeals for the Sixth Circuit, replacing the deceased Shackelford Miller Jr., and the Senate confirmed the nomination on April 5, 1967, and Combs received his commission the same day. Because of the rules of the federal judiciary, Combs had to liquidate his business and banking assets and severely restrict contact with many of his political acquaintances to avoid potential conflicts of interest with cases he might adjudicate on the Court of Appeals. He expressed frustration that the cases that came before the court were frequently appealed to the Supreme Court, which often gave little weight to the opinions rendered by the Court of Appeals. Consequently, he resigned from the court on June 5, 1970, and joined the Louisville law firm of Tarrant, Combs, and Bullitt (later Wyatt, Tarrant & Combs).
With the end of Governor Nunn's term approaching, a rivalry for leadership of the state Democratic party developed between Lieutenant Governor Wendell H. Ford, who had served as Combs' chief administrative assistant during his gubernatorial term, and Julian M. Carroll, speaker of the state House of Representatives. As soon as Combs resigned from the Court of Appeals, Democratic leaders began asking him to seek the party's gubernatorial nomination in 1971, uniting the party behind him rather than splintering it between Ford and Carroll. In June 1970, Carroll announced his intent to run for lieutenant governor, indicating that he would like to serve under Combs as governor. While Combs considered whether or not to seek the nomination, Ford declared his candidacy. Days later, Combs also entered the race.
Combs and Ford advocated similar platforms, but Combs encouraged the state's teachers to become more politically active, negotiating higher salaries and better benefits for themselves, while Ford was critical of educators becoming involved in politics and only advocated more spending on education if the state could afford it. In his oral history of Combs, Robinson noted that Ford, thirteen years Combs' junior, "came across better on television" and that many voters in the state felt that Combs must have ulterior motives in leaving a judgeship that paid a salary of $42,500 for the governorship, which paid only $30,000 annually. Catholics were also upset that Combs had married his second wife, Helen Clark Rechtin, just forty-three days after his divorce from Mabel Hall was finalized on July 18, 1969. (Combs and Hall had been separated for five years prior to finalizing
Bert Combs