IACHR

Precautionary Measures

The mechanism for precautionary measures is established in Article 25 of the Rules of Procedure of the IACHR. The Rules of Procedure establish that, in serious and urgent situations, the Commission may, on its own initiative or at the request of a party, request that a State adopt precautionary measures to prevent irreparable harm to persons or to the subject matter of the proceedings in connection with a pending petition or case, as well as to persons under the jurisdiction of the State concerned, independently of any pending petition or case. The measures may be of a collective nature to prevent irreparable harm to persons due to their association with an organization, a group, or a community with identified or identifiable members. As a result, the number of precautionary measures granted does not reflect the number of persons protected by their adoption; as can be seen below, many of the precautionary measures issued by the IACHR protect more than one person and, in certain cases, groups of persons such as communities or indigenous peoples. Moreover, the Rules of Procedure establish that the granting of such measures and their adoption by the State shall not constitute a prejudgment on the violation of the rights protected by the American Convention on Human Rights or other applicable instruments. On August 1, 2013 the amended Rules of Procedure entered into force and established that ¨the decisions granting, extending, modifying or lifting precautionary measures shall be adopted through reasoned resolutions¨.

Hearings on Precautionary Measures »

PM 30/14 – Fernando Alcibíades Villavicencio Valencia et al., Ecuador

On March 24, 2014, the IACHR requested that precautionary measures be adopted for Fernando Alcibíades Villavicencio Valencia, Cléver Jiménez, and Carlos Eduardo Figueroa Figueroa, in Ecuador. The request for precautionary measures had been presented in the context of individual petition P-107-14, which alleges violations of the rights enshrined in Articles 8 (right to fair trial), 9 (freedom from ex post facto laws), 13 (freedom of thought and expression), and 25 (judicial protection), in conjunction with the general obligations established in Articles 1(1) and 2 of the American Convention on Human Rights. Specifically, the petitioners asked for precautionary measures “in order for the State to suspend the implementation of the cassation ruling issued against them on January 14, 2014, due to the grave and irreparable harm the process itself and the subsequent judgment would have on their rights to life, physical integrity, personal liberty, political rights, and freedom of expression.” During the proceedings, the State presented reports on February 8 and 28, 2014. For their part, the petitioners presented additional reports on February 9 and 27 and March 17 and 19, 2014. After analyzing the allegations of fact and law presented by the parties, the Commission believes that the information presented shows prima facie that the rights of Messrs. Fernando Alcibíades Villavicencio Valencia, Cléver Jiménez, and Carlos Eduardo Figueroa Figueroa are in a serious, urgent situation of irreparable harm. Therefore, pursuant to Article 25(1) of its Rules of Procedure, the Commission asks the State of Ecuador to immediately suspend the effects of the January 14, 2014, decision issued by the Cassation Court of the National Court of Justice’s Specialized Chamber on Criminal, Military-Criminal, Police-Criminal, and Transit Matters, until the IACHR has ruled on individual petition P-107-14. Read the resolution here in Spanish.

PM 110/14 - Ramiro Hernández Llanas, United States

On March 19, 2014, the Commission requested the adoption of precautionary measures pursuant to Article 25(1) of its Rules of Procedure in order to avoid irreparable harm to Ramiro Hernández Llanas who was sentenced to death in the United States. The request for precautionary measures was accompanied by a petition alleging violation of rights recognized in the American Declaration of the Rights and Duties of Man. That petition was given the number P-455/14. Through its resolution, the Commission requested the Government of the United States to abstain from executing Ramiro Hernández Llanas until the IACHR has ruled on the merits of the individual petition filed on his behalf. Read the resolution here.

PM 374/13 – Gustavo Francisco Petro Urrego, Colombia

On March 18, 2014, the IACHR requested that precautionary measures be adopted for Gustavo Francisco Petro Urrego, Mayor of the city of Bogotá, D.C., Colombia. The request for precautionary measures had been presented in the context of individual petition P-1742-13, which alleges violations to the rights to humane treatment (Article 5), to a fair trial (Article 8), to participate in government (Article 23), to equal protection under the law (Article 24), and to judicial protection (Article 25 of the American Convention on Human Rights). Specifically, the petitioners ask that, “in order to prevent irreparable harm to persons or to the subject matter of the petition, the judicial action being brought by the Attorney General’s Office against Gustavo Petro be suspended.” During the proceeding, the State submitted information on January 10, 21, and 29, and February 7 and 24, 2014. For their part, the petitioners presented information on December 9, 11, 18, and 19, 2013; January 3, 13, 16, and 20, 2014; February 6, 24, and 26, 2014; and March 3, 4, 5, 6, and 18, 2014. After analyzing the allegations of fact and law presented by the parties, the Commission believes that the information presented shows prima facie that the situation involving the political rights of Mr. Gustavo Francisco Petro Urrego, elected by popular vote as Mayor of Bogotá and currently in office, is serious and urgent, as the implementation of the effects of the decision removing him from office and ruling him ineligible to exercise his political rights could render ineffective an eventual decision on petition P-1742-13. Therefore, pursuant to Article 25(1) of its Rules of Procedure, the Commission requests that the State of Colombia immediately suspend the effects of the decision of December 9, 2013, issued and ratified by the Attorney General’s Office on January 13, 2014, so as to ensure that Mr. Gustavo Francisco Petro Urrego can exercise his political rights and complete his term as Mayor of Bogotá, for which he was elected on October 30, 2011, until the IACHR has ruled on individual petition P1742-13. Read the resolution here in Spanish.

PM 57/14 - Pete Carl Rogovich, United States

On March 4, 2014, the Commission requested the adoption of precautionary measures pursuant to Article 25(1) of its Rules of Procedure in order to avoid irreparable harm to Pete Carl Rogovich who was sentenced to death in the United States. The request for precautionary measures was accompanied by a petition alleging violation of rights recognized in the American Declaration of the Rights and Duties of Man. That petition was given the number P-1663/13. Through its resolution, the Commission requested the Government of the United States to abstain from executing Pete Carl Rogovich until the IACHR has ruled on the merits of the individual petition filed on his behalf. Read the resolution here.

PM 453/13 – Daniel Ramos Alfaro, Mexico

On February 20, 2014, the IACHR requested that precautionary measures be adopted for Daniel Ramos Alfaro, 21 years old, whose life and physical integrity are said to be at grave risk, inasmuch as his whereabouts or fate have been unknown since October 2, 2013. The request for precautionary measures alleges that Daniel Ramos Alfaro was detained by purported members of the Mexican military forces while he was traveling to the community of San Martín, after giving classes at the school in the community of Betania. Given the nature of the situation reported, the Commission asked the State for information based on the functions spelled out in Article XIV of the Inter-American Convention on Forced Disappearance of Persons. The State of Mexico responded by means of a report on January 22, 2014, and the IACHR also received additional information from the petitioner on February 1, 2014. After analyzing the allegations of fact and law, the Commission believes that the information shows in principle that the situation of the young man Daniel Ramos is serious and urgent; his rights to life and physical integrity are said to be at grave risk given that to this day, 141 days after his disappearance, his whereabouts or fate reportedly remain unknown. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asks the State of Mexico to adopt the measures necessary to determine the situation and whereabouts of Daniel Ramos Alfaro, in order to protect his rights to life and physical integrity, and to inform the Commission as to the steps taken to investigate the facts that gave rise to the adoption of this precautionary measure. Read resolution here: in Spanish.

PM 408/13 – Members of the Movimiento “Reconocido,” Dominican Republic

On January 30, 2014, the IACHR requested that precautionary measures be adopted for the members of the Movimiento “Reconocido” [“Recognized” Movement], in the Dominican Republic. The request for precautionary measures alleges that members of the Movimiento “Reconocido” received threats to their lives and physical integrity as a result of the criticism and protest these human rights defenders had exercised against Judgment 168/13, a decision by the Constitutional Court of the Dominican Republic denationalizing thousands of Dominicans of Haitian descent. After analyzing the allegations of fact and law presented, the Commission believes that the information shows in principle that the members of the Movimiento “Reconocido” are facing a serious and urgent situation, as their lives and physical integrity are said to be at grave risk due to the death threats they are said to have received. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asks the Dominican Republic to adopt the necessary measures to protect the lives and physical integrity of the members of the Movimiento “Reconocido”; to guarantee that the members of this movement can carry out their activities as human rights defenders without being subject to acts of violence and harassment in the exercise of their functions; and to come to an agreement with the beneficiaries and their families on the measures to be adopted. The Commission also asked the State to keep it informed as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that such incidents do not happen again. Read resolution here: in Spanish.

MC 457/13 – Members of “Asociación para una Vida Mejor de Honduras” [Association for a better life in Honduras] (APUVIMEH)

On January 22, 2014, the Inter-American granted precautionary measures for the members of “Asociación para una Vida Mejor de Honduras” [Association for a better life in Honduras] (APUVIMEH). The request for precautionary measures indicates that, due to their activities of defense, protest and protection of the rights of lesbian, gay, bisexual, trans and intersex persons (LGBTI) in Honduras, members of the organization would have become the object of killings, threats, harassment and violence against them, in retaliation for their activities. Specifically, the request alleges that members of the association carried out awareness raising and protection activities and ran a shelter house called “Casa Renacer” [House of Rebirth] where they took care of persons living with HIV and other sexually transmitted diseases. Acts of aggression and assault against their members would have taken place in a context of violence against LGBTI persons, which would be the cause of approximately 115 killings in the last years, cases that would have ended in impunity. The IACHR asked that the State of Honduras take the necessary steps to ensure the life and physical integrity of the members of “Asociación para una Vida Mejor de Honduras” [Association for a better life in Honduras] (APUVIMEH), that it come to an agreement with the beneficiaries as to the measures to be taken, and that it inform the Commission about the steps taken to investigate the facts that gave rise to the adoption of precautionary measures. Read resolution here: in Spanish.

PM 8/13 – Persons Deprived of Liberty at the Porto Alegre Central Prison, Brazil

On December 30, 2013, the IACHR requested that precautionary measures be adopted for persons deprived of liberty at the Porto Alegre Central Prison (PCPA), in Brazil. The request for precautionary measures alleges that these individuals are at risk due to poor detention conditions, extreme overcrowding, and lack of State control over various parts of the facility, among other situations, all of which could affect the prisoners’ right to life and personal integrity. After analyzing the allegations of fact and law submitted by the petitioners and the State, the Commission believes that the information presented suggests that the situation of those deprived of liberty at the PCPA is serious and urgent, as their lives and physical integrity are said to be at grave risk. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asked the State of Brazil to adopt the necessary measures to protect the lives and personal integrity of the inmates at the Porto Alegre Central Prison; provide hygienic conditions at the facility and adequate medical treatment for the inmates, in line with whatever medical conditions they may have; and implement measures designed to recover security control over all areas of the prison, following international human rights standards and protecting the lives and personal integrity of all the inmates. Read resolution here: in English.

PM 195/13 – Leaders and Human Rights Defenders from the Community of Nueva Esperanza and the Regional Council of the Florida Sector, Honduras

On December 24, 2013, the IACHR requested that precautionary measures be adopted for Adonis Romero and other individuals identified in the documents provided, who are said to be leaders and human rights defenders from the community of Nueva Esperanza and the Regional Council (Patronato Regional) of the Florida sector, in the municipality of Tela, department of Atlántida. The request for precautionary measures alleges that the proposed beneficiaries are at risk because of their work to oppose various mining projects reportedly being carried out in the area. On August 28, 2013, the IACHR requested information from the State. As of the date this measure was granted, the State had not responded to the request for information. After analyzing the allegations of fact and law submitted by the petitioners, the Commission believes that the information presented suggests that Adonis Romero and other alleged leaders and human rights defenders from the community of Nueva Esperanza and the Regional Council of the Florida sector are facing a serious and urgent situation, as their lives and physical integrity are said to be at serious risk. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asked the State of Honduras to adopt the necessary measures to guarantee the lives and physical integrity of the 18 leaders and human rights defenders identified, who belong to the Nueva Esperanza community and the Regional Council of the Florida Sector; reach agreement with the beneficiaries and their families on the measures to be adopted; and inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that such incidents do not happen again. Read resolution here: in English.

PM 416/13 – Members of the Movimiento Amplio por la Dignidad y la Justicia (MADJ) and their Families, Honduras

On December 19, 2013, the IACHR requested that precautionary measures be adopted for the members of the Movimiento Amplio por la Dignidad y la Justicia (MADJ) and their families, in Honduras. The request for precautionary measures alleges that the members of the MADJ have been receiving a series of threats and acts of harassment and violence because of their work in defense of the natural resources of the indigenous peoples in the Locomapa sector of the department of Yoro. After analyzing the allegations of fact and law submitted by the petitioners, the Commission believes that the information presented suggests that the situation of the MADJ members and their respective families is serious and urgent, as their lives and physical integrity are said to be under threat and at grave risk. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asked the State of Honduras to adopt the necessary measures to preserve the lives and physical integrity of the 18 members of the Movimiento Amplio por la Dignidad y la Justicia (MADJ) and their family members; reach agreement with the beneficiaries and their families on the measures to be adopted; and inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that such incidents do not happen again. Read the resolution here: in English or in Spanish.

PM 367/13 – Persons Deprived of Liberty at the Pedrinhas Prison Complex, Brazil

On December 16, 2013, the IACHR requested that precautionary measures be adopted for the individuals incarcerated at the Pedrinhas Prison Complex, in Brazil. The request for precautionary measures alleges that these individuals are at risk from acts of violence. After analyzing the allegations of fact and law presented by the petitioners and the State, the Commission believes that the information presented suggests that those deprived of liberty at the Pedrinhas Prison Complex are facing a grave and urgent situation, as their life and safety are reportedly threatened and at serious risk. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asked the State of Brazil to adopt the necessary measures to prevent loss of life and harm to the physical integrity of those deprived of liberty at the Pedrinhas Prison Complex; to immediately reduce the levels of overcrowding; and to investigate the incidents that gave rise to the adoption of this precautionary measure so that they do not happen again. Read the resolution here in English or in Portuguese.

PM 304/13 - Patrice Florvilus and members of the organization “Défense des Opprimés”, Haiti

On November 27, 2013, the IACHR requested that precautionary measures be adopted in favor of Patrice Florvilus and the members of the organization “Défense des Opprimés”. The request for precautionary measures alleged that these persons were in a situation of risk, due to a series of threats, harassment and persecution in retaliation of the activities they carry out in defense of human rights in Haiti. On October 2, 2013, the IACHR requested information from the State, but did not receive a response. In addition, the applicants provided new information concerning alleged new risk situations the organization is supposedly facing. Consequently, in compliance with Article 25 of its Rule of Procedure, the Commission requested the State of Haiti to adopt the necessary measures to preserve the life and the personal integrity of Patrice Florvilus and the members of the organization “Défense des Opprimés”, to agree on the measures to be adopted with the beneficiaries and his representatives and to inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that they do not happen again. Read the Resolution here in English or in French.

PM 410/13 - José Luis Zubmaguera Miranda and Family, Cuba

On November 21, 2013, the IACHR requested that precautionary measures be adopted in favor of José Luis Zubmaguera Miranda and his family, in Cuba. The request for precautionary measures alleges that José Luis Zubmaguera Miranda had been shot 7 times by police officers, in the context of his detention during an investigation on a stolen bicycle. The applicants affirm that his relatives, who supposedly witnessed these facts, are presumably subject to a series of intimidations perpetrated by police officers due to the complaints filed in this regard. After analyzing the factual and legal arguments put forth by the applicants, the Commission considers that the information presented shows prima facie that José Luis Zubmaguera Miranda and his family are in a serious and urgent situation, as their lives and personal integrity are threatened and at severe risk. Consequently, in compliance with Article 25 of its Rule of Procedure, the Commission requested the State of Cuba to adopt the necessary measures to preserve the life and the personal integrity of José Luis Zubmaguera Miranda and his family, to agree on the measures to be adopted with the beneficiaries and his representatives and to inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that they do not happen again. Read the resolution here: in English or in Spanish.

PM 409/13 - Asociación Pro-Búsqueda de Niñas y Niños Desaparecidos regarding El Salvador

On November 21,2013, the IACHR requested that precautionary measures be adopted in favor of the members of the “Asociación Pro-Búsqueda de Niñas y Niños Desaparecidos” (Association for the Search of Disappeared Children). The request for precautionary measures indicated that on November 14, 2013, three armed men had allegedly broken into the organization, and had subjugated the security staff, the motorcyclist and the President of the organization. Subsequently, they had proceeded to burned down the files of the institution and destroyed their work equipment. After analyzing the factual and legal arguments put forth by the applicants, the Commission considers that the information presented shows prima facie that the members of “Asociación Pro-Búsqueda de Niñas y Niños Desaparecidos” are in a serious and urgent situation, as their lives and personal integrity are threatened and at severe risk. Consequently, in compliance with Article 25 of its Rule of Procedure, the Commission requested the State of El Salvador to adopt the necessary measures to preserve the life and the personal integrity of the members of “Asociación Pro-Búsqueda de Niñas y Niños Desaparecidos”, and to inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that they do not happen again. The resolution on this precautionary measure is maintained under confidentiality, due to the request of the petitioners not to disclose the identity of some of the members of the organization.

PM 338/13 – Lorenzo Santos Torres and Family, Mexico

On November 8, 2013, the IACHR requested that precautionary measures be adopted for Lorenzo Santos Torres and his family, in Mexico. The request for precautionary measures received by the Commission on October 7, 2013, alleges that the life and personal integrity of Lorenzo Santos Torres and his family are at risk, in the context of a social and agrarian conflict in Santiago Amoltepec. On October 24, the IACHR requested information from the State, which presented its report on October 29. The petitioners provided additional information on October 29 and 31. After analyzing the allegations of fact and law submitted by both parties, the Commission believes that the information presented suggests that Lorenzo Santos Torres and his family are threatened and at serious risk. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asked the State of Mexico to adopt the necessary measures to protect the lives and personal integrity of Lorenzo Santos Torres and his family; reach agreement with the beneficiaries and their representatives on the measures to be adopted; and inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that they do not happen again. Read the resolution here: in English or in Spanish.

PM 245/13 – Iván Hernández Carrillo, Cuba

On October 28, 2013, the IACHR requested that precautionary measures be adopted for Iván Hernández Carrillo, in Cuba. The request for precautionary measures received by the Commission on August 1, 2013, alleges that Iván Hernández Carrillo—reportedly a journalist serving as Secretary General of the Confederation of Independent Workers of Cuba—is at risk and has been the target of physical attacks, threats, arrests, and acts of intimidation perpetrated by agents of Cuba’s Department of State Security, as a result of his work as a human rights defender. The petitioners provided additional information on August 27 and September 18, 2013. On August 3, 2013, the IACHR requested information from the State. As of the date the Commission adopted the resolution on precautionary measures, the State had not responded to the request for information. After analyzing the allegations of fact and law submitted by the petitioners, the Commission believes that the information presented suggests that Iván Hernández Carrillo’s situation is serious and urgent. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asked the State of Cuba to adopt the necessary measures to protect the life and personal integrity of Iván Hernández Carrillo; reach agreement with the beneficiary and his representatives on the measures to be adopted; and inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that they do not happen again. Read the resolution here: in English or in Spanish.

PM 264/13 – Damas de Blanco, Cuba

On October 28, 2013, the IACHR requested that precautionary measures be adopted for the members of the organization “Damas de Blanco” (“Ladies in White”), in Cuba. The request for precautionary measures received by the Commission on August 13, 2013, alleges that the members of “Damas de Blanco” are targets of threats, harassment, and acts of violence in retaliation for their peaceful demonstrations to draw attention to the situation of political dissidents in Cuba. The petitioners provided additional information on September 17 and 26. After analyzing the allegations of fact and law submitted by the petitioners, the Commission believes that the information presented suggests that the situation of the members of “Damas de Blanco” is serious and urgent, as their lives and personal integrity are reportedly being threatened and are at serious risk. Therefore, pursuant to Article 25 of the IACHR Rules of Procedure, the Commission asked the State of Cuba to adopt the necessary measures to protect the lives and personal integrity of the members of the organization “Damas de Blanco”; reach agreement with the beneficiaries and their representatives on the measures to be adopted; and inform the Commission as to the steps taken to investigate the incidents that gave rise to the adoption of this precautionary measure so that they do not happen again. Read the resolution here: in English or in Spanish.

PM 301/13 – Buenaventura Hoyos Hernández, Colombia

On October 4, 2013, the Commission requested the adoption of precautionary measures pursuant to Article 25 (1) of its Rules of Procedure, in order to avoid irreparable harm to Buenaventura Hoyos Hernández, 18 years old, who is allegedly in a serious and urgent situation, since his rights to life and personal integrity are allegedly at risk, given that to this date his whereabouts or fate are not known. The Commission requested the State of Colombia to adopt the necessary measures to determine the status and whereabouts of Buenaventura Hernández Hoyos, in order to protect his rights to life and personal integrity. The Commission also requested the State to report on the actions taken to investigate the facts that led to the adoption of this precautionary measure. Read the resolution here: in English or in Spanish.

PM 186/13 - Carlos Eduardo Mora y familia, Colombia

On October 3, 2013 the IACHR requested the adoption of precautionary measures in favor of Carlos Eduardo Mora, who is a corporal of the National Army of Colombia, in the intelligence specialty and is currently in active duty. The request for precautionary measures affirms that Carlos Eduardo Mora and his family allegedly face a risk situation due the participation of the corporal as a witness in the trials related to the presumed extrajudicial executions, supposedly perpetrated by members of the Army of Colombia. The Colombian State provided information about the case on September 19 2013. Te Commission concluded that Carlos Eduardo Mora and his nuclear family are in a situation of seriousness and urgency, since their rights to life and personal integrity are presumably threatened and at serious risk. According to Article 25 of its Rule of Procedure, the Commission requested the State of Colombia to adopt the necessary measures to preserve the life and the personal integrity of Carlos Eduardo Mora and his nuclear family and to agree on the measures to be adopted with the beneficiaries, taking into account the role as witness of Carlos Eduardo Mora, the nature of the procedure in which he is involved and the fact that he is an active member of the Army. Likewise, the Commission requested the State to report on the actions taken to investigate the facts that gave rise to the precautionary measures, in order to prevent its repetition. Read Resolution here Read the Resolution here.

PM 157/13 - Members of Union des Citoyens Conséquents pour le Respect des Droits de l'Homme, Haiti.

On September 23, 2013, the Commission requested the adoption of precautionary measures pursuant to Article 25 (1) of its Rules of Procedure, in order to avoid irreparable harm to life and personal integrity of members of the Union des Citoyens Conséquents pour le Respect des Droits de l'Homme ("Consistent Citizens Union for Human Rights", UCCRDH), who claim to be in a dangerous situation due to a number of threats, harassment and acts of violence allegedly in retaliation to the work they perform in defense of human rights in Haiti. Through its resolution, the Commission requested the Government of Haiti to take the necessary measures to guarantee the life and personal integrity of Jean Guernal Degand, Jimmy Simplis, Marieclaude Marcelin, Réginald Henry y Saintilma Verdieu. The Commission also requested the Government of Haiti to report on the actions taken to investigate the facts that led to the adoption of this precautionary measure, and to inform, within 15 days from the date of this resolution, on the adoption of precautionary measures required, and update such information regularly. Read the Resolution here: in Spanish, English or in French.

PM 255/13 - Robert Gene Garza, United States

On August 16, 2013 the Commission requested the adoption of precautionary measures pursuant to Article 25(1) of its Rules of Procedure in order to avoid irreparable harm to Robert Gene Garza who was sentenced to death in the United States. The request for precautionary measures was accompanied by a petition alleging violation of rights recognized in the American Declaration of the Rights and Duties of Man. That petition was given the number P-1278/13. Through its resolution, the Commission requested the Government of the United States to abstain from executing Mr. Robert Gene Garza until the IACHR has ruled on the merits of the individual petition filed on his behalf. Read Resolution 1/2013 on PM 255/13

PM 137/13 – Girls Deprived of Liberty in adult detention centres, Jamaica

On July 31, 2013, the IACHR granted precautionary measures in favor of girls deprived of liberty in adult detention centres, in Jamaica. The request for precautionary measures alleges that girls are detained with adults and in conditions that presumably place them at risk of irreparable harm. The applicants also allege the presumed failure of the pertinent authorities to take measures and prevent the girls from hurting themselves and/or suffer abuses by adults and peers. The IACHR requested information to the State in May and June 2013, and later received information indicating that the risk situation allegedly continues. The IACHR granted precautionary measures to protect the life and physical integrity of the girls deprived of liberty in adult detention centres. Specifically, the Inter-American Commission requested the State of Jamaica to adopt all necessary measures to protect the life and personal integrity of the beneficiaries, providing the physical and mental medical care required by the beneficiaries and investigate the allegation of sexual and physical abuses; to provide the IACHR with a list of all girls being held at adult detention centres, containing their names, ages, current judicial status and health situations; and to adopt the necessary measures to transfer all girls from the Horizon Adult Remand Centre, Fort August Adult Correctional Centre and all other adult detention centres, to appropriate facilities, taking into account their legal status and any medical or phsychological needs, and preventing any children to be deprived of liberty in adult detention centres.

PM 7/3 - Vilasson Séraphin and others, Haiti

On July 24, 2013 , the IACHR granted precautionary measures in favor of Vilasson Seraphin, Jeanne Joseph, Johanne Jean-Claude, Jean-Rony Figaro, Roselande Jourdain y Lucmane Louis-Jean, in Haiti. The request for precautionary measures alleges that on December 29, 2012, André Seraphin, member of several civil society organizations, had been kidnapped from his home in the city of Cap- Haitien, allegedly by a group of people who work under orders of a Senator. The next day his body had allegedly been found dead with signs of torture. The request alleges that André had been murdered for allegedly denounced arbitrary acts committed by the gang and the support of the Senator to such acts. Additionally, it is alleged that the father and mother of the victim and the applicant organization, were being persecuted and threatened by the gang and by the presumptive Senator, for trying to seek justice in the case of André Seraphin. On April 2, 2013, the IACHR requested information from both parties on the alleged risk of the proposed beneficiaries, but the State has not so far responded. The IACHR asked the State of Haiti to adopt the necessary measures to guarantee the life and integrity of Vilasson Seraphin, Jeanne Joseph, Johanne Jean-Claude, Jean-Rony Figaro, Roselande Jourdain y Lucmane Louis-Jean, and agree on the measures to be adopted with the beneficiaries and their representatives. The Commission also requested the State to report on the actions taken to investigate the facts that gave rise to the precautionary measures. The IACHR also requested the State to report to the Commission on the implementation of these measures.

PM 259/02 - Detainees in the US Military Base in Guantanamo
EXTENSION

On July 23, 2013, the Inter-American Commission on Human Rights extended, on its own initiative, the scope of the precautionary measures in favor of the detainees held by the United States at the Naval Station in Guantanamo Bay, in order to require the closure of that detention facility. The extension was based on the failure of the United States to comply with the precautionary measures already in force in favor of the detainees since 2002, the persistence of situations of prolonged and indefinite detention, and allegations of widespread abuse and mistreatment, including unnecessary and humiliating searches, the force feeding of detainees who have chose to participate in a hunger strike, and the increasing segregation and isolation of detainees. In addition, the information received by the Commission indicates the response of the authorities to the hunger strike has included forced feeding, unnecessary and humiliating searches, and the increased isolation of the detainees. Given these reports, the Commission requested specific information from the US Government on April 19, 2013, and reiterated that request on June 11, 2013. The Commission notes the Government’s submission of July 11, 2013, but observes that it fails to provide detailed information in response to the specific questions posed. The Commission calls the Government’s attention to the international standards that require respect for personal autonomy and dignity. Taking into account the human rights obligations of the United States as a Member State of the OAS, and given the ongoing risk of irreparable harm to the rights of detainees that is aggravated with the passage of time, the Inter-American Commission has decided to extend the scope of these precautionary measures and require the Government of the United States to proceed to immediately close the detention facilities at the Naval Station at Guantanamo Bay; to transfer the detainees to home or third countries in observance of human rights guarantees, principally the obligation of non-refoulement; to release those who have already been cleared for transfer should be expedited; and to house in appropriate conditions and accord applicable due process rights to any detainees subject to trial.

PM 125/13 –Iris Yassmín Barrios Aguilar et al., Guatemala

On June 28, 2013, the IACHR granted precautionary measures for Iris Yassmín Barrios Aguilar, Patricia Isabel Bustamante García, and Pablo Xitumul de Paz, members of the First Court for High-Risk Crimes in the Guatemalan department of Guatemala. The requests for precautionary measures allege that Iris Yassmín Barrios Aguilar, Patricia Isabel Bustamante García, and Pablo Xitumul de Paz are at risk as a result of carrying out their judicial functions in various cases involving organized crime and cases against members of the military allegedly responsible for grave human rights violations such as the “Plan de Sánchez” and “Las Dos Erres” massacres, among other matters. In particular, the petitioners refer to the role the beneficiaries have had in the case against former President José Efraín Ríos Montt, which is reportedly leading to polarization in Guatemala. In this apparent context, the petitioners say that various anonymous pamphlets had been circulated to undermine the legitimacy of their work by claiming that their involvement in the case represented a “threat to peace and stability in the country,” which could have serious consequences for their right to life and safety. Moreover, in recent weeks the IACHR has received new information suggesting a series of alleged flaws in the protection arrangements provided for these individuals. In this regard, the petitioners have noted that because their level of risk has allegedly been exacerbated, it is necessary to adopt special protection measures for the members of the First Court for High-Risk Crimes. The IACHR asked the State of Guatemala to take the necessary steps to guarantee the life and physical integrity of Iris Yassmín Barrios Aguilar, Patricia Isabel Bustamante García, and Pablo Xitumul de Paz, and to come to an agreement with the beneficiaries and their representatives as to the measures to be adopted, taking into consideration the implementation proposal sent by the representatives as to the entity that could coordinate the protection measures.

PM 279/12 – Luisa Fransua, Rafael Toussaint, et al., Dominican Republic

On June 10, 2013, the IACHR granted precautionary measures for Luisa Fransua, Rafael Toussaint, and another 48 individuals and their 32 children, in the Dominican Republic. According to information provided by those seeking the precautionary measures, the beneficiaries of this measure are being denied birth records, identity cards, and voter IDs, or their documents are being withheld or invalidated. They indicate that this situation is blocking their access to basic services, allegedly impeding the exercise of their rights, especially their rights to health and education. The petitioners maintain that the individuals identified in the request for precautionary measure could be deported to Haiti at any time. The IACHR asked the State of the Dominican Republic to adopt the necessary measures to ensure the protection of Luisa Fransua, Rafael Toussaint, and another 48 individuals and their 32 children, so as to keep them from being expelled or deported from the territory of the Dominican Republic, and to take the necessary steps so that the beneficiaries and their children have access to identification documents that guarantee them access to basic services such as education and health, until such time as the Commission rules on the petitions before it. The IACHR also asked the State of the Dominican Republic to reach agreement with the beneficiaries and their representatives on the measures to be adopted. This precautionary measure was also granted because the beneficiares are also the alleged victims in petitions presented to the Commission, which have been registered with the numbers 1960-12 and 389-13. In this sense, the decision to grant this precautionary measure seeks to ensure that the Commission’s eventual decisions on the merits of these petitions do not become abstract.

PM 155/13 - Caleb Orozco, Belize

On May 29, 2013, the IACHR granted precautionary measures for Caleb Orozco, in Belize. The request for precautionary measures indicates that Caleb Orozco is in a state of risk as a result of his work defending the rights of lesbian, gay, bisexual, trans, and intersex persons in Belize. Specifically, the petition alleges that Caleb Orozco has been subject to harassment and attacks at his home and on the streets, and he has received death threats via social media. It further alleges that even though he has filed complaints with the police, the authorities are not providing measures to protect his life and safety. The IACHR asked that the State of Belize take the necessary steps to ensure the life and physical integrity of Caleb Orozco, that it come to an agreement with the beneficiary as to the measures to be taken, and that it inform the Commission about the steps taken to investigate the facts that gave rise to the adoption of precautionary measures.

PM 114/13 - B, El Salvador

On April 29, 2013, the IACHR granted precautionary measures in favor of “B,” in El Salvador. The identity of the beneficiary is kept confidential at the request of the petitioners and/or beneficiary. The request for precautionary measures alleges that the Ministry of Health and the Committee of the hospital where “B” has been admitted have determined that “B” suffers from various pathologies, that her pregnancy has a high risk of death for the mother, and that the fetus is anencephalic. In addition, it alleges that those health authorities have determined that the effect of time without the implementation of the recommended medical treatment could affect the rights to life, integrity and health of the mother. The petitioners expressed that, even though they had requested the State authorities, including the Supreme Court of Justice, that the treatment recommended by the specialized doctors be given, there is no final answer to date. After requesting information to the State, which ratified that there is still no definite response from the State authorities, the IACHR granted precautionary measures to protect the life, personal integrity and health of “B.” Specifically, the Inter-American Commission requested the State of El Salvador to adopt the necessary measures to implement the treatment recommended by the Medical Committee of the National Hospital Specialized in Maternity “Dr. Raúl Arguello Escalón,” aiming to protect the life, personal integrity and health of “B,” and that any measure is adopted in consultation with the beneficiary and her representatives.
Considering that the State of El Salvador had allegedly not adopted the necessary measures to safeguard the personal integrity of “B”, on May 27 2013, the IACHR requested provisional measures to the Inter-American Court of Human Rights. The Inter-American Court ordered provisional measures on May 29 2013, and lifted them on August 19, 2013.

PM 273/11 - Fray Tomás González Castillo, Ruben Figueroa, staff Home- Shelter migrants 'La 72' and others, Mexico


On April 19, 2013, the IACHR granted precautionary measures in favor of Fray Tomás González Castillo, Ruben Figueroa , staff Home- Shelter migrants 'La 72' and migrants who are in the same place, in Mexico. The request for precautionary measures alleges that the persons mentioned are at a risk related to the security situation of migrants in the area, alleged actions of retaliation for their activities as human rights defenders, the alleged permanent harassment of a person called ' La Chaquira', among others. The Commission has taken note on the implementation of a series of protective measures in favor of the members of the Home -Shelter ' La 72', by the state authorities. However, the Commission has continued receiving information on alleged constant threats and harassment against the persons mentioned. The Commission asked the State of Mexico to adopt the necessary measures to guarantee the life and physical integrity of Fray Tomás González Castillo, Ruben Figueroa, staff Home-Shelter migrants 'La 72' and migrants who are therein. The Commission also requested the State to conclude the protective measures adopted with the beneficiaries and their representatives, and report on security measures taken to carry out their work as human rights defenders without interference. The Commission also requested the State to report on the actions taken to investigate the facts that gave rise to the precautionary measures, and to report to the Commission on the implementation of these measures.

PM 391/12 - Toribio Jaime Muñoz Gonzalez and others, Mexico


On April 16, 2013, the IACHR granted precautionary measures in favor of Toribio Jaime Muñoz González, Guadalupe Muñoz Veleta , Jaime Munoz Veleta, Óscar Munoz Veleta , Hugo Muñoz Veleta, Nemesio Solís González, Luis Romo Muñoz , and Óscar Guadalupe Cruz Bustos, in Mexico. The request for precautionary measures alleges that the persons concerned have disappeared. The Commission notes that the State had taken some measures to find the location of the alleged disappeared. However, such measures have not yielded progress that sheds light on the facts. The Commission asked the State of Mexico to adopt, immediately, all necessary measures to determine the status and whereabouts of Toribio Jaime Muñoz González, Guadalupe Muñoz Veleta, Jaime Muñoz Veleta, Óscar Muñoz Veleta, Hugo Muñoz Veleta, Nemesio Solís González, Luis Romo Muñoz, y Óscar Guadalupe Cruz Bustos, and to protect their life and personal integrity. The Commission also requested the State to report to the Commission on the implementation of these measures, and to report on the adoption of the same, and to update such information regularly.

PM 84/13 – Bernardo Aban Tercero, United States

On April 4, 2013, the IACHR granted precautionary measures for Bernardo Aban Tercero, who was sentenced to death in the United States. The request for precautionary measures is accompanied by a petition on the alleged violation of rights enshrined in the American Declaration; this petition was registered under number P-1752-09. The Commission asked the United States to refrain from carrying out the death penalty until the Commission has the opportunity to rule on the petitioner’s claim regarding the alleged violation of the American Declaration, so as to not render ineffective the processing of that claim in the inter-American system.

PM 52/13 – 567 Families Living in Grace Village, Haiti

On March 26, 2013, the IACHR granted precautionary measures for the residents of the Grace Village camp for displaced persons, in Carrefour, Haiti. The request for precautionary measures indicates that there is a risk to the life and integrity of the displaced individuals who currently live in Grace Village, a camp built to temporarily house people who were displaced by the 2010 earthquake. The petitioners contend that some 567 families live there, under inhumane and unhealthy conditions, with very limited access to food, potable water, and health-care services. They also point to an alleged context of extrajudicial forced evictions, carried out without following legal procedures, allegedly with the use of violence, and purportedly without providing living alternatives or relocation. In addition, the petition claims that women and children are especially vulnerable, particularly due to the intimidation and sexual harassment on the part of camp managers, and that people are targets of reprisals when they take action to defend the rights of the camp residents. The IACHR asked the State of Haiti to adopt the necessary measures to prevent the use of force and violence in any eviction, and in particular to ensure that the actions of public authorities and private individuals do not present a risk to the life and physical integrity of the camp residents. The Commission also requested that the State implement effective security measures in the camp, including adequate patrols carried out around and inside the camp and police stations set up near the camp; to this effect, the Commission asked the State that these security measures be implemented with special regard for women and children. Further, the Commission asked the State to ensure that the residents have access to drinking water. The measures should be worked out with the beneficiaries and their representatives, and the Commission requested that the camp’s residents committee and grassroots women’s groups be ensured full participation in the planning and execution of all measures implemented for the residents, including those designed to prevent sexual violence and other types of violence in the camp. Finally, the Commission asked the State to keep it informed as to the steps taken to investigate the incidents that led to the adoption of precautionary measures.

PM 34/13 - X, Cuba

On February 14, 2013, the IACHR granted precautionary measures in favor of X, in Cuba. The IACHR withholds her identity because she is a minor. The request for precautionary measures alleges that X, 15 years old, was attacked as a consequence of defending a member of the "Damas de Blanco" ("Ladies in White"), who is a relative of the child. The request alleges that the child was attacked with a knife, on November 4, 2012, by a relative of a Police Captain. In addition, it alleges that in January 2013, psychologists of the Department of Legal Medicine conducted an interrogation to the child, without the presence of her mother, allegedly in an attempt to make her change her account of what had happened. The request also alleges that State authorities threatened to commit her to a mental hospital. The IACHR requested that the State of Cuba adopt the necessary measures to guarantee the life and physical integrity of X, to adopt the measures in consultation with the beneficiary and her representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 370/12 – Patients at the Federico Mora Hospital, Guatemala


On November 20, 2012, the IACHR granted precautionary measures for 334 patients at the Federico Mora Hospital in Guatemala. The request for precautionary measures alleges that everyone who is hospitalized at the Federico Mora Hospital is in a situation of risk. According to the petition, the 334 hospitalized patients, including children, share the same space with mentally disabled individuals who have been prosecuted and sentenced for various crimes. The petition adds that agents of the National Civilian Police and staff of the prison system are responsible for guarding the facility, and use threats, harassment, and acts of violence against the patients. The information presented to the IACHR indicates that there is physical and sexual abuse against women and children, and those patients have been denied proper medical care and given psychiatric treatment that does not suit their pathology. The Commission was also informed that some patients are being locked in isolation rooms, and that there is a practice of tying patients to chairs, among other allegations. The IACHR asked the government of Guatemala to adopt any necessary measures to guarantee the life and personal integrity of those hospitalized at the Federico Mora Hospital, and especially to provide proper medical care to patients, in accordance with each person's pathologies; to ensure the separation of the children from the adults and to seek special measures in light of the principle of the best interest of the child; to separate patients who have been prosecuted and sentenced, and who are being deprived of liberty under court order, from the other patients at the hospital, and to ensure that the protection of these patients is provided by unarmed hospital staff; to restrict the use of isolation rooms to the situations and conditions established in international standards regarding persons with mental disabilities; and to implement immediate prevention measures so that no patients, especially women and children, are subject to acts of physical, psychological, or sexual violence on the part of other patients, security agents, or hospital staff. The IACHR also asked the State of Guatemala to reach agreement with the beneficiaries and their representatives on the measures to be adopted. In this regard, the IACHR informed the government that it believes it is necessary for the parties, by common agreement, to present a timetable for implementing these precautionary measures, after having held the first meeting on coordination of the measures. Finally, the IACHR requested that the government inform the Commission about the steps taken to investigate the events that led to the adoption of these precautionary measures

PM 350/12 – Yoani María Sánchez Cordero, Cuba


On November 9, 2012, the IACHR granted precautionary measures for Yoani María Sánchez Cordero and her family, in Cuba. The request for precautionary measures indicates that Yoani María Sánchez Cordero is at risk, due to the publication of several articles on an Internet blog about the human rights situation in Cuba. Specifically, the petitioners allege that she has had threats, acts of harassment, and smear campaigns waged against her. Moreover, the petition indicates that Yoani María Sánchez Cordero and her husband were arrested on October 4, 2012, and that as a result of being assaulted by police agents, Yoani María Sánchez Cordero ended up with a broken tooth and contusions. Yoani María Sánchez Cordero was again arrested on November 8, 2012. The IACHR asked the State of Cuba to adopt the necessary measures to guarantee the life and physical integrity of Yoani María Sánchez Cordero and her family; to come to an agreement with the beneficiary and her representatives on the measures to be adopted; and to inform the IACHR on the actions taken to investigate the facts that gave rise to the adoption of precautionary measures.

PM 354/12 – Sonia Garro, Cuba


On November 8, 2012, the IACHR granted precautionary measures for Sonia Garro, in Cuba. According to the request for precautionary measures, the life and integrity of Sonia Garro—a member of the organization Damas de Blanco (Ladies in White) of the Fundación Afrocubana Independiente (Independent Afro-Cuban Foundation)—are at imminent risk. The petition states that Sonia Garro is suffering from various illnesses and is being deprived of her liberty in the Occidente Women's Prison, where she has reportedly been subject to threats. As a result of an incident in the prison, the petition adds, the delivery of food to her by family members was suspended, and this had been her only source of food due to her medical condition. The IACHR asked the State of Cuba to adopt the necessary measures to guarantee the life and personal integrity of Sonia Garro; reach agreement with the beneficiary and her representatives as to the measures to be adopted; and inform the Commission on the steps taken to investigate the facts that gave rise to the adoption of precautionary measures.

PM 388/12 – Edgar Ismael Solorio Solís et al., Mexico


On November 6, 2012, the IACHR granted precautionary measures for the three sons of Ismael Urrutia and Manuela Marta Solís, who were reportedly leaders of the organization "El Barzón," as well as for the members of that organization, in Mexico. According to the request for precautionary measures, "El Barzón" is an organization that advocates for a healthy environment in the state of Chihuahua, Mexico. The petition alleges that since July 2012, all of the organization's members have been subject to continual death threats. It indicates that on October 13, 2012, members of a mining company allegedly beat up Ismael Urrutia, after which he sought protection from the competent authorities; this protection allegedly was not implemented. The petitioners add that on October 22, 2012, Ismael Urrutia and Manuela Marta Solís were reportedly killed, after which their three sons requested protection, without having received a response. The IACHR requested that the State of Mexico adopt the necessary measures to guarantee the life and physical integrity of Edgar Ismael Solorio Solís, Erick Solorio Solís, Uriel Alejandro Solorio Solís, Joaquín Solorio Urrutia, Felipe Solorio Urrutia, César Solorio Urrutia, Heraclio Rodríguez, Martín Solís Bustamante, Luis Miguel Rueda Solorio, Ángel Rueda Solís, and Siria Solís. In addition, the IACHR asked that the State of Mexico reach agreement with the beneficiaries and their representatives as to the measures to be adopted, and that it inform the Commission on the steps taken to investigate the facts that gave rise to the adoption of precautionary measures.

PM 484/11 – José Daniel Ferrer García, Cuba


On November 5, 2012, the IACHR granted precautionary measures for José Daniel Ferrer García, in Cuba. According to the request for precautionary measures, José Daniel Ferrer García was deprived of his liberty and held in solitary confinement, and was threatened by security guards on numerous occasions, in February, April, May, and July of 2012. In particular, the request indicates that police agents threatened that they would "lock up his wife" and "leave his three children on the street, without their parents." The IACHR asked the State of Cuba to adopt the necessary measures to guarantee the life and personal integrity of José Daniel Ferrer García; reach agreement with the beneficiary and his representatives as to the measures to be adopted; and inform the Commission on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 363/12 – Mario Joseph, Haiti


On October 19, 2012, the IACHR granted precautionary measures for Mario Joseph, in Haiti. According to the request for precautionary measures, the life and personal integrity of Mario Joseph, director of the nongovernmental organization Bureau des Avocats Internationaux (BAI), are at risk. The request contends that Mario Joseph has been subject to threats and acts of harassment in recent months, allegedly because of his activities in defending human rights. It indicates that he received several death threats per day after participating, in February 2012, in a press conference on the criminal proceedings underway against former President François Duvalier and that, starting in September 2012, security agents had interrogated BAI members, searched the organization's facilities, and persecuted Mario Joseph. The IACHR asked the State of Haiti to adopt any necessary measures to guarantee the life and personal integrity of Mario Joseph, come to an agreement with the beneficiary and his representative on the measures to be adopted, and inform the Commission on the steps taken to judicially investigate the events that led to the adoption of precautionary measures.

PM 225/12 – Alfamir Castillo, Colombia


On October 17, 2012, the IACHR granted precautionary measures for Alfamir Castillo, in Colombia. The request for precautionary measures alleges that Alfamir Castillo was subject to repeated death threats and persecution. According to the petition, on August 28, 2012, someone on a motorcycle fired two shots into the air while passing by her, and on October 10, 2012, an unknown individual pointed a gun at her chest and threatened her with death. The request indicates that these actions were linked to her participation in the criminal investigation into the death of her son. The IACHR asked the government of Colombia to adopt any necessary measures to guarantee the life and physical integrity of Alfamir Castillo, reach agreement with the beneficiary and her representatives on the measures to be adopted, and inform the Commission about the steps taken to investigate the events that led to the adoption of precautionary measures.

PM 342/12 – César Adán Alvarenga Amador and Roberto García Fúnez, Honduras


On October 3, 2012, the IACHR granted precautionary measures for César Adán Alvarenga Amador and Roberto García Fúnez, in Honduras. The request for precautionary measures alleges that the two human rights defenders, members of the Movimiento Amplio por la Dignidad y Justicia (Broad Movement for Dignity and Justice), had been subject to threats and harassment in recent months. The Commission was also informed that on August 18, 2012, unidentified individuals had entered the home of César Adán Alvarenga, where they reportedly destroyed several of his belongings, though they did not steal anything of value. The petitioners indicated that the incident was reported to the relevant authorities, but that protection measures had not yet been implemented. The IACHR requested that the government of Honduras adopt any necessary measures to guarantee the life and physical integrity of César Adán Alvarenga Amador and Roberto García Fúnez, reach agreement with the beneficiaries and their representatives on the measures to be adopted, and inform the Commission about the steps taken to investigate the events that led to the adoption of precautionary measures.

PM 207/12 – Telma Yolanda Oqueli Veliz and family, Guatemala


On August 24, 2012, the IACHR granted precautionary measures in favor of Telma Yolanda Oqueli Veliz and family, in Guatemala. The request for precautionary measures alleges that Telma Yolanda Oqueli Veliz, a human rights defender and member of the community group North Front of the Metropolitan Area Peoples in Resistance, has allegedly received threats in the context of the opposition of this group to a mining project. It is indicated that on June 13, 2012, Telma Yolanda Oqueli Veliz was shot in the back, and was hospitalized several days. It is also alleged that her brother was threatened. The IACHR requested the State of Guatemala to adopt the necessary measures to guarantee the life and physical integrity of Telma Yolanda Oqueli Veliz, to adopt the measures in consultation with the beneficiaries and their representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 152/11 – Members of the House for Migrants “Frontera Digna”, Municipality of Piedras Negras, Coahuila, México


On August 17, 2012, the IACHR granted precautionary measures in favor of the members of the House for Migrants “Frontera Digna”, Municipality of Piedras Negras, Coahuila, México. Initially, the IACHR requested information to the State and took note of the implementation of protection measures in favor of the members of the organization on the part of the competent authorities. Notwithstanding, the IACHR has continued to receive information that indicates that the threats and harassment against them have continued. The IACHR requested the State of México to adopt the necessary measures to guarantee the life and physical integrity of the members of the House for Migrants “Frontera Digna”, to adopt the measures in consultation with the beneficiaries and their representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 269/10 – Manuel Junior Cortéz Gómez and Yolanda Gómez Torres, Colombia


On June 22, 2012, the IACHR granted precautionary measures in favor of Manuel Junior Cortéz Gómez and Yolanda Gómez Torres, in Colombia. The request for precautionary measures alleges that Manuel Junior Cortéz Gómez is the only survivor of an alleged massacre of a soccer team, which was allegedly executed in October 2009 in Venezuela, near the border with Colombia, by a grup that calls itself Fuerza de Liberacion Bolivariana. The request alleges that after the alleged massacre, Manuel Junior Cortéz Gómez and Yolanda Gómez Torres cooperated with the Judiciary, and that afterwards the threats and harassment against them started. Additionally, it is indicated that on June 6, 2012, Manuel Junior Cortéz Gómez was attacked and stabbed, and was hospitalized in serious condition. The IACHR requested the State of Colombia to adopt the necessary measures to guarantee the life and physical integrity of Manuel Junior Cortéz Gómez and Yolanda Gómez Torres, to adopt the measures in consultation with the beneficiaries and their representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 163/12 – Damaris Moya Portieles and daughter, Cuba


On June 12, 2012, the IACHR granted precautionary measures in favor of Damaris Moya Portiele and her daughter, 5 years old, in Cuba. The request for precautionary measures alleges that Damaris Moya Portiele is a human rights defender, and that she had been deprived of her liberty several times as a result of her participation in demonstrations in her country. The request also alleges that on May 2, 2012, during a vigile organized for freedom in Cuba, agents of the Security police again deprived her of her liberty, beat her, and threatened with raping her daughter. The IACHR requested the State of Cuba to adopt the necessary measures to guarantee the life and physical integrity of Damaris Moya Portiele and her daughter, to adopt the measures in consultation with the beneficiary and her representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 131/12 – Hernán Henry Díaz, Colombia


On On June 11, 2012, the IACHR granted precautionary measures in favor of Hernán Henry Díaz, in Colombia. The IACHR received information on April 25 and 27, 2012, about the alleged forced disappearance of Hernan Henry Díaz, a peasant leader, member of the Coordination of Social, Peasant, Afrodescendant and Indigenous Organizations of the Department of Putumayo, member of the National Federation of Agricultural Farming Unions, and leader of the social and political movement Marcha Patriótica (Patriotic March). According to the information received, the last time that anyone heard from Hernán Henry Díaz was on April 18, 2012, when through a text message he communicated that he was in his way to Bogota to participate in the launching of the “Marcha Patriótica”. Through the precautionary measure, the IACHR requested the State of Colombia to immediately adopt the necessary measures to determine the situation and whereabouts of Hernán Henry Díaz and to protect his life and personal integrity; and to inform the Commission about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 21/11 – Blanca Velázquez Díaz et al., Mexico


On May 29, 2012, the IACHR granted precautionary measures in favor of Blanca Velázquez Díaz, José Enrique Morales Montaño, Cecilia Medina and other members of the Centro de Apoyo al Trabajador (CAT, or Support Center for Workers), in Mexico. The request for precautionary measures alleges that the CAT members have been victims of harassment, following, and threats, due to their involvement in actions to promote the protection of labor rights in Mexico. Subsequently, they informed that on May 15, 2012, defender José Enrique Morales Montaño was kidnapped and resulted seriously injured, and that after this, the telephonic threats have increased. The IACHR requested the State of Mexico to adopt the necessary measures to guarantee the life and physical integrity of Blanca Velázquez Díaz, José Enrique Morales Montaño, Cecilia Medina and other CAT members, to adopt the measures in consultation with the beneficiaries and their representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 60/12 – Members of the Triqui Indigenous Community in the San Pedro River Valley, San Juan Cópala, Putla de Guerrero, Oaxaca, Mexico


On May 29, 2012, the IACHR granted precautionary measures in favor of 76 members of the Triqui Indigenous Community in the San Pedro River Valley, San Juan Cópala, Putla de Guerrero, Oaxaca, Mexico. The request for precautionary measures alleges that the 76 members of this community, who currently live in the San Pedro River Valley, are in a risk situation. They informed that they had been displaced from San Juan Copala by armed actors operating in the area, and that currently they are victims of threats, acts of violence and harassment, aiming to displace them again. In this context, on May 8, 2012, a pick-up truck allegedly entered with violence in the community, firing against the houses, resulting in the death of three persons. The IACHR requested the State of Mexico to adopt the necessary measures to guarantee the life and physical integrity of the 76 members of the Triqui Indigenous Community in the San Pedro River Valley, San Juan Cópala, Putla de Guerrero, Oaxaca, Mexico, to adopt the measures in consultation with the beneficiaries and their representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 399/09 – 15 workers of Progreso Radio, Honduras


On May 25, 2012, the IACHR decided to amplify Precautionary Measure 399/09, in favor of Jerson David Rivera Amaya, a journalist of Radio Progreso, in Honduras. According to the information received, Jerson David Rivera Amaya has been receiving threats since October 2011. It is also alleged that the authorities refused to take his complaint. The IACHR included Jerson David Rivera as a beneficiary of the precautionary measure and requested the State of Honduras to inform the IACHR on the consultation with the beneficiaries to agree on its implementation. The PM 399/09, which protects several workers of Progreso Radio in Honduras, was separated of PM 196/09 on April 1, 2011.

PM 77/12 – Alberto Patishtán Gómez, Mexico


On May 24, 2012, the IACHR granted precautionary measures for Alberto Patishtán Gómez, in Mexico. The request for precautionary measures contends that the health of Alberto Patishtán Gómez, who is being deprived of his liberty, is in grave danger due to the worsening of an alleged glaucoma. The request indicates that without access to proper medical treatment, which is contingent upon the care he may receive under custody of the State, Alberto Patishtán Gómez could lose his vision permanently. The IACHR asked the government of Mexico to instruct the relevant authorities to conduct the medical exams that would make it possible to assess the beneficiary's health and to provide him with proper treatment. It also asked the government to reach agreement with the beneficiary and petitioner on the measures to be adopted, ensuring that he and anyone he authorizes has access to the beneficiary's medical file.

PM 153/12 – Niurka Luque Alvarez, Cuba


On May 16, 2012, the IACHR granted precautionary measures in favor of Niurka Luque Álvarez, in Cuba. The request for precautionary measures alleges that Niurka Luque Álvarez suffers epilepsy attacks, and that she had not received medical attention, or medicines, or authorization for her family members to provide the medicines needed for her condition. The IACHR requested the State of Cuba to adopt the necessary measures to guarantee the life and personal integrity of Niurka Luque Álvarez; to instruct the competent authorities to conduct the medical exams that allow to evaluate the health situation of the beneficiary and to authorize the adequate treatment for her condition, including the provision of medicines needed to treat epilepsy; and to adopt these measures in consultation with the beneficiary and her representatives.

PM 323/11 – Members of the Comité Permanente por la Defensa de los Derechos Humanos and its Sections, Colombia


On May 9, 2012, the IACHR granted precautionary measues in favor of Edgar Montilla, Martín Sandoval, Athemay Sterling and Diego Alejandro Martínez Castillo, and of the members of the Sections Bogota, Huila, Nariño and Arauca of the Comité Permanente por la Defensa de los Derechos Humanos (CPDH, or Permanent Committee for the Defense of Human Rights), en Colombia. The request for precautionary measures alleges that the members of the CPDH in Bogota and 14 sections in the country have been subject of threats and harassment since 2009. They allege that, although they requested protection measures, some have not been granted and the others are inssuficient and ineffective. The IACHR requested the State of Colombia to adopt the necessary measures to guarantee the life and physical integrity of Edgar Montilla, Martín Sandoval, Athemay Sterling and Diego Alejandro Martínez Castillo, as well as other members of the Sections in Bogotá, Hila, Nariño and Arauca of the Comité Permanente por la Defensa de los Derechos Humanos; to adopt the measures in consultation with the beneficiary and her representatives, and to inform the Commission on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 485/11 – X, Mexico


On May 8, 2012, the IACHR granted precautionary measures in favor of the child X, in Mexico. The IACHR withholds her identity because she is a minor. The request for precautionary measures alleges that on July 17, 2011, aproximately at 1 a.m., a group of 15 armed policemen and paramilitaries entered the house of the family of X, in the State of Chiapas. The request further alleges that the father of the family was not present, and that the mother tried to wake up their four children, but X did not wake up in time and the mother escaped with the other three children. The current whereabouts of the child X is undetermined. The IACHR requested the State of Mexico to immediately adopt the necessary measures to determine the situation and whereabouts of the child X and to protect her life and personal integrity, and to inform the Commission on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 13/12 – Members of the Human Rights Lawyers Group, Guatemala


On May 2, 2012, the IACHR granted precautionary measures in favor of the members of the Human Rights Lawyers Group (Bufete Jurídico en Derechos Humanos), in Guatemala. The request for precautionary measures alleges that the members of the group have been subject to threats and harassment that is allegedly linked to their work, specifically with the cases related to the period of internal armed conflict. The IACHR requested the State of Guatemala to adopt the necessary measures to guarantee the life and physical integrity of the members of the Human Rights Lawyers Group, to adopt the measures in consultation with the beneficiaries and their representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 104/12 – Penitentiary Services, Buenos Aires Province, Argentina


On April 13, 2012, the IACHR granted precautionary measures in favor of persons detained in units 46, 47 and 48 of the Buenos Aires Province Penitentiary Services, Argentina. The request for precautionary measures alleges that there exist patterns of violence in this units, which are allegedly linked with the alleged presence of knives and drugs, the alleged inactivity of guards regarding the protection of the prisoners, the alleged practice to imprison in the same cell or space persons who display enmity to each other, and the overcrowding, among other factors that allegedly resulted in the death of at least four persons deprived of liberty. The IACHR requested the State of Argentina to adopt the necessary measures to guarantee the life and personal integrity of all persons deprived of liberty in units 46, 47 and 48 of the Buenos Aires Province Penitentiary Services.

PM 101/12 – Julius O. Robinson, United States


On April 9, 2012, the Commission granted precautionary measures in favor of Julius O. Robinson, who was sentenced to death in the United States. The request for precautionary measures was accompanied by a petition alleging violation of rights recognized in the American Declaration of the Rights and Duties of Man. That petition was classified as P-561/12. The Commission requested that the United States refrain from executing the death sentence until the Commission has had an opportunity to reach its decision on the petitioner's claim of violation of the American Declaration, so as not to render moot the filing of that claim with the inter-American system.

PM 102/12 – José Humberto Torres and family, Colombia


On April 5, 2012, the IACHR informed the State of Colombia its decision to separate José Humberto Torres from Precautionary Measure 83/99, whose beneficiaries are members of the Committee of Solidarity with Political Prisioners, in order to give special follow-up to his situation and that of his family. This decision is based in information received by the Commisson that indicates that alleged paramilitaries in jails and members of the criminal gang “Los Rastrojos” have offered 200 million pesos to whomever kills José Humberto Torres. The IACHR requested the State of Colombia to adopt the necessary measures to guarantee the life and physical integrity of José Humberto Torres and his family; to to adopt the measures in consultation with the beneficiaries and their representatives, and to inform on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 69/12 – Leonel Asdrúbal Dubón Bendfelt et al, Guatemala


On April 5, 2012, the IACHR granted precautionary measures in favor of Leonel Asdrúbal Dubón Bendfelt et al., in Guatemala. The request for precautionary measures alleges that Leonel Asdrúbal Dubón Bendfelt has been followed for approximately one year, as a result of his work as a human rights defender and the cases brought forward by the association he heads. It also alleges that the threats intensified in recent months, and that he has been threatened directly and by telephone. The IACHR requested the State of Guatemala to adopt the necessary measures to guarantee the life and physical integrity of Leonel Asdrúbal Dubón Bendfelt, his immediate family, and the members of the association El Refugio de la Niñez (Children's Refuge); to adopt the measures in consultation with the beneficiaries and their representatives and to inform the Commission about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 208/10 – Estela Ángeles Mondragón, México


On March 1, 2012, the IACHR granted precautionary measures in favor of Estela Ángeles Mondragón, in México. The request for precautionary measures alleges that Estela Ángeles Mondragón is in a situation of risk, due to threats and acts of harassment and violence against her, which are allegedely a consequence of her involvement in several judicial processes followed in favor of the Indigenous Community Rarámuri de Baqueachí. The IACHR requested the State of Mexico to adopt the necessary measures to guarantee the life and physical integrity of Estela Ángeles Mondragón; to adopt the measures in consultation with the beneficiary and her representatives; and to inform the Commission about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 406/11 - Emilio Palacio, Carlos Nicolás Pérez Lapentti, Carlos Pérez Barriga and César Pérez Barriga, Ecuador


On February 21, 2011, the IACHR granted precautionary measures in favor of Emilio Palacio, Carlos Nicolás Pérez Lapentti, Carlos Pérez Barriga and César Pérez Barriga, in Ecuador. This decision is based on information received by the Commission since November 2011 regarding a process of libel and slander promoted by President Rafael Correa against journalist Emilio Palacio, the three directors of the newspaper El Universo - Carlos Perez Nicolas Lapentti, Carlos Perez Perez and Cesar Barriga Barriga - and the newspaper El Universo. According to the information provided, on February 15, 2012 the National Court of Justice of Ecuador confirmed the judgment sentencing the beneficiaries to three years in prison and ordering to pay 40 million dollars. The facts reported to the Commission could cause irreparable damage to the right to freedom of expression of Emilio Palacio, Carlos Nicolás Pérez Lapentti, Carlos Pérez Barriga and César Pérez Barriga. Accordingly, the Commission on Human Rights requested the Government of Ecuador to immediately suspend the effects of the judgment of February 15, 2012, to ensure the right to freedom of expression of Emilio Palacio, Carlos Nicolás Pérez Lapentti, Carlos Pérez Barriga and César Pérez Barriga. In addition, the Commission decided to hold a hearing on March 28, 2012, to receive information from the parties on the adoption and observance of these precautionary measures. Following the hearing, the Commission will decide whether to continue these measures, modify them or lift them.

On March 9, 2012, the IACHR the IACHR lifted these precautionary measures and archived the file, after receiving a communication, dated February 29, 2012, in which the petitioners asked the measures to be lifted, given that the reasons of immediate urgency that has motivated them had ceased. In view of the decision to lift the measures, the IACHR also decided to cancel the hearing initially scheduled for March 28, 2012.

PM 357/11 – Héctor Rolando Medina, United States


On February 7, 2012, the Commission granted precautionary measures in favor of Hector Rolando Medina, who was sentenced to death in the United States. The request for precautionary measures was accompanied by a petition alleging violation of rights recognized in the American Declaration of the Rights and Duties of Man. That petition was classified as P-1907/11. The Commission requested that the United States refrain from executing the death sentence until the Commission has had an opportunity to reach its decision on the petitioner's claim of violation of the American Declaration, so as not to render moot the filing of that claim with the inter-American system.

PM 7/12 – Edgar Tamayo Arias, United States


On January 18, 2012, the Commission granted precautionary measures in favor of Edgar Tamayo Arias, who was sentenced to death in the United States. The request for precautionary measures was accompanied by a petition alleging violation of rights recognized in the American Declaration of the Rights and Duties of Man. That petition was classified as P-15/12. The Commission requested that the United States refrain from executing the death sentence until the Commission has had an opportunity to reach its decision on the petitioner’s claim of violation of the American Declaration, so as not to render moot the filing of that claim with the inter-American system.

PM 351/11 – Ananías Laparra Martínez, México


On January 18, 2012, the IACHR granted precautionary measures in favor of Ananías Laparra Martínez, in Mexico. The request for precautionary measures alleges that the life and health of Ananías Laparra Martínez, who is deprived of liberty in a detention center in Tapachulas, Chiapas, is in grave danger, due to a critical health condition he suffers. It is also alleged that the necessary medical examination to have a diagnosis and to advice on treatment has not taken place. They also allege that his representatives have not had access to his medical file. The IACHR requested that the State of Mexico adopt the necessary measures to protect the physical integrity of Ananías Laparra Martínez; instruct the competent authorities to conduct the medical examinations necessary to make an evaluation of the health status of the beneficiary and authorize an adequate treatment; and to come to an agreement with the beneficiary and his representatives on the measures to be adopted, guaranteeing that he and the persons he authorizes have access to his medical file.

PM 349/11 – Rocío San Miguel, Venezuela


On January 18, 2012, the IACHR granted precautionary measures in favor of Rocío San Miguel and her daughter, in Venezuela. The request for precautionary measures alleges that Rocío San Miguel was victim of harassment and threats, including death threats she received at her home, as a consequence of her activities as a member of the non governmental organization Control Ciudadano (Citizen Control). The request also alleges that the authorities have not investigated the origin of such threats and harassment acts, and that they did not implement measures to guarantee her life, integrity and security. The IACHR requested the Government of Venezuela to adopt the necessary measures to guarantee the life and physical integrity of Rocío San Miguel and her daughter, who is a minor; to adopt measures in consultation with the beneficiary and her representative; and to inform the Commission about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 196/09 – Honduras


During the 143 period of sessions; the Commission decided to proceed gradually in separating from MC 196.09, those matters on which information is updated and suggest the continued risk to the beneficiaries. In such situations, it will assign a new number of precautionary measures corresponding to the year 2009. In this process, The IACHR has already separated the following matters: MC 398.09 HO (Esdras Amado Lopez) 399.09 MC (Workers Progress Journal) HO 400.09 (Berta Oliva and members of the Committee of Relatives of Detained and Disappeared in Honduras (COFADEH)); 401.09 HO (Take Rasel Antonio Flores and his family).

PM 471/11 – Jurijus Kadamovas and others, United States


On December 27, 2011 the Commission requested the immediate adoption of precautionary measures pursuant to Article 25(1) of its Rules of Procedure in order to avoid irreparable harm of Jurijus Kadamovas, German Sinnistera, Arboleda Ortiz, Robert L. Bolden, Iouri Mikhel, and Alejandro Umana who were sentenced to death penalty. The petitioner alleges, inter alia, Vienna Convention claims, discrimination based on nationality, inhumane prison conditions, and lack of medical attention. With regard to the latter, the petitioner alleges that Jurijus Kadamovas has not received psychiatric or psychological support in spite of his requests; and that Robert L. Bolden is not receiving treatment for his type 1diabetes. The Commission requested the United States take the measures necessary to preserve the life and physical integrity of Jurijus Kadamovas and others so as not to hinder the processing of the case before the inter-American system classified as number P 1285-11.

PM 18/09 – Paul Pierre, United States


On December 22, the IACHR granted precautionary measures for Mr. Paul Pierre, of Haitian origin, who might be deported back to Haiti at any time now. According to the parties seeking the precautionary measures, Mr. Pierre is suffering from “esophageal dysplasia” and is on a liquid diet ingested through a tube. The Commission therefore asked the United States not to deport Mr. Paul Pierre back to Haiti until the Commission issues its decision on petition P-1431/08, which is currently being processed with the Commission.

PM 470/11 – Iván Teleguz, United States


On December 22, 2011, the IACHR granted precautionary measures for Mr. Iván Teleguz, sentenced to death by the Rockingham Circuit Court in the state of Virginia. Accompanying the request for precautionary measures was a petition alleging violation of rights protected under the American Declaration, which the Commission classified as number P-1528-11. The Commission asked the United States to refrain from executing the death sentence until it has had an opportunity to decide the merits of the petitioner’s claim alleging violation of the American Declaration, so as not to render moot the processing of that petition with the inter-American system.

PM 465/11 – Virgilio Maldonado Rodríguez, United States


On December 21, 2011, the IACHR granted precautionary measures for Virgilio Maldonado Rodríguez, a Mexican national sentenced to death in the state of Texas. The request seeking precautionary measures was filed together with a petition alleging violation of rights protected under the American Declaration. Classified as P-1762/11, the petition specifically alleges that the United States did not take into account Mr. Maldonado’s mental disability; it argued that under the American Declaration, the death penalty constituted cruel punishment. Mr. Maldonado was one of the Mexican citizens included in the judgment delivered by the International Court of Justice in 2004 in the Case concerning Avena and other Mexican nationals (Mexico v. United States), in which the ICJ ordered the United States to review and reconsider the guilty verdicts and sentences given to the Mexican citizens named in the judgment. The Commission asked the United States to refrain from executing the death sentence until the Commission has had an opportunity to reach a decision on the petitioner’s claim of an alleged violation of the American Declaration, so as not to render moot the processing of that petition with the inter-American system.

PM 393/10 − Luis Álvarez Renta, Dominican Republic


On December 15, 2011, the IACHR granted precautionary measures for Luis Álvarez Renta. The Commission’s decision was based on a request alleging that the personal integrity and health of Luis Álvarez Renta were in grave danger. It contends that Mr. Renta is currently incarcerated in the Najayo Model Prison in San Cristóbal, where his health condition is critical. He is being denied the back surgery that specialists have recommended for him. According to a medical report from the Abreu Clinic, dated November 16, 2011, Mr. Renta has Dejerine-Roussy syndrome caused by lumbosacral stenosis. This condition requires a lumbar laminectomy to decompress the spinal cord. The surgery must be done as soon as possible to avoid severe neurological damage.” The Commission therefore requested that the Government of the Dominican Republic: 1) adopt the measures necessary to protect Mr. Álvarez Renta’s personal integrity; 2) instruct the competent authorities to have the proper medical tests done to evaluate the beneficiary’s health and authorize proper treatment for his ailments, and 3) adopt these measures in concert with the beneficiary and his representatives.

PM 463/11 – Nelson Iván Serrano Sáenz, United States


On December 15, 2011, the IACHR granted precautionary measures for Mr. Nelson Iván Serrano Sáenz, an Ecuadoran national facing the death penalty in Florida. The request for precautionary measures was accompanied by a petition alleging violation of rights recognized in the American Declaration of the Rights and Duties of Man. That petition was classified as P-1643/11. The Commission requested that the United States refrain from executing the death sentence until the Commission has had an opportunity to reach its decision on the petitioner’s claim of violation of the American Declaration, so as not to render moot the filing of that claim with the inter-American system.

PM 370/11 — Sara Marta Fonseca Quevedo, Cuba


On December 6, 2011, the IACHR granted precautionary measures for Sara Marta Fonseca Quevedo in Cuba. The request seeking precautionary measures alleges that Sara Marta Fonseca Quevedo, Executive Secretary of the Pro Human Rights Party in Cuba and a delegate of the Rosa Parks Feminist Civil Rights Movement in Havana, was harassed when she sought medical treatment at state-run health care institutions, presumably because of her political position and because she is an advocate for human rights. The request also states that Sara Marta Fonseca Quevedo was detained four times in 2011, often by violent means. The parties requesting the precautionary measures state that Sara Marta Fonseca Quevedo was in custody from September 24 to October 24, 2011 and that because of the violence allegedly used on her during her detention, a pre-existing back condition was aggravated, leaving her unable to stand up on her own. The Commission therefore asked the Cuban Government to take the necessary measures to ensure the life and physical integrity of Sara Marta Fonseca Quevedo and to guarantee that she would not be harassed by staff of state-run hospitals; that in concert with the beneficiary and her representative it arrange the measures it will take, and that it report on the measures undertaken to investigate the facts that necessitated adoption of precautionary measures.

PM 262/11 – Ten Persons alleged to have been disappeared, Mexico


On December 2, 2011, the IACHR granted precautionary measures for 10 members of the Zapotengo Pacheco Eco-tourism Cooperative Association. The parties requesting the precautionary measures allege that on July 13, 2010, Nemonio Vizarretea Vinalay, Fidel Espino Ruiz, Gregorio Hernández Rodríguez, Andrés Vizarretea Salinas, Luis Vizarretera Salinas, Juan Carlos Vizarretea Salinas, Benito Salinas Robles, Juan Antonio Feria Hernández, Isauro Rojas Rojas and Adelardo Espino Carmona had boarded a bus bound for Matamoros in the state of Tamaulipas, where they were planning to purchase vehicles. On July 14, 2010, the individuals in question reportedly spoke with family members to advise them that they had reached Tamaulipas. The request seeking precautionary measures states that they have not been heard from since. The parties requesting precautionary measures assert that on March 18, 2011, the Office of the Attorney General of the Republic allegedly advised them that the disappeared persons had been detained and were being held in Morelos, but did not indicate exactly where. On July 15, 2011, officials of the city of Morelos allegedly reported that an error had been made in the data and that the persons in question had never been in custody and were never arraigned. The parties seeking the precautionary measures point out that to date, they have no information on the situation or whereabouts of the persons identified as having disappeared. The Commission therefore asked the Government of Mexico: 1) to immediately adopt the measures necessary to determine the situation and whereabouts of Nemonio Vizarretea Vinalay, Fidel Espino Ruiz, Gregorio Hernández Rodríguez, Andrés Vizarretea Salinas, Luis Vizarretea Salinas, Juan Carlos Vizarretea Salinas, Benito Salinas Robles, Juan Antonio Feria Hernández, Isauro Rojas Rojas and Adelardo Espino Carmona; and 2) to report the measures taken to investigate the facts that necessitated the precautionary measures.

PM 425/11 – X, Argentina


On November 18, 2011, the IACHR granted precautionary measures in favor of X, in Argentina, whose identity is being withheld at the request of the beneficiary. The application for the precautionary measures alleged that X had been the victim of attacks by agents of the Federal Correctional Complex No 2 of Marcos Paz, where he was detained. He adds that as a result of such attacks, should have been admitted to a hospital in Buenos Aires. The Commission requested the State to adopt the necessary measures to guarantee the life and physical integrity of X, and coordinate the measures to be adopted with the recipient and his representative, and report on actions taken to investigate the events that led to the adoption of this precautionary measure.

PM 422/11 – Lucía Carolina Escobar Mejía, Cledy Lorena Caal Cumes, and Gustavo Girón, Guatemala


On November 14, 2011, the IACHR granted precautionary measures for Lucía Carolina Escobar Mejía, Cledy Lorena Caal Cumes, and Gustavo Girón, in Guatemala. The request for precautionary measures claims that the journalists Lucía Carolina Escobar Mejía and Gustavo Girón, employed by the daily El Periódico and other media outlets, have received threats in retribution for publishing articles about alleged acts of violence committed by a group styling itself the “Panajachel Security Commission.” The request further contends that this group operates with the acquiescence of the local authorities. In addition, it claims that Cledy Lorena Caal Cumes has received threats on account of her participating in the investigation into the disappearance of her partner, in which members of that group are suspected of involvement. The Commission asked the State to take the steps necessary to ensure the lives and persons of Lucía Carolina Escobar Mejía, Cledy Lorena Caal Cumes, and Gustavo Girón, to agree on the measures to be adopted with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 255/11 – Nasa people of Toribio, San Francisco, Tacueyo, and Jambalo Reservations, Colombia


On November 14, 2011, the IACHR granted precautionary measures on behalf of the members of the Nasa people of Toribio, San Francisco, Tacueyo, and Jambalo Reservations, in Colombia. The request for precautionary measure claims that the members of the Nasa indigenous people in these four adjacent reservations are facing high levels of risk because of the armed conflict in the north of Cauca department, and that they have suffered murders, forced disappearances, and other acts of violence. The application further states that although the authorities have acknowledged the risks facing the Nasa people, the appropriate measures necessary to protect them have not been adopted. The Commission asked the State to take the steps necessary to ensure the lives and persons of the members of the Nasa people of Toribio, San Francisco, Tacueyo, and Jambalo Reservations, to agree on the measures to be adopted with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 255/11 – Nasa people of Toribio, San Francisco, Tacueyo, and Jambalo Reservations, Colombia


On November 14, 2011, the IACHR granted precautionary measures on behalf of the members of the Nasa people of Toribio, San Francisco, Tacueyo, and Jambalo Reservations, in Colombia. The request for precautionary measure claims that the members of the Nasa indigenous people in these four adjacent reservations are facing high levels of risk because of the armed conflict in the north of Cauca department, and that they have suffered murders, forced disappearances, and other acts of violence. The application further states that although the authorities have acknowledged the risks facing the Nasa people, the appropriate measures necessary to protect them have not been adopted. The Commission asked the State to take the steps necessary to ensure the lives and persons of the members of the Nasa people of Toribio, San Francisco, Tacueyo, and Jambalo Reservations, to agree on the measures to be adopted with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 17/10 – Inhabitants of the community of Omoa, Honduras


On November 8, 2011, the IACHR granted precautionary measures on behalf of the inhabitants of the community of Omoa, in Honduras. The request for precautionary measures claims that the lives and persons of the approximately 8,000 inhabitants of Omoa are at risk because of the liquid petroleum gas storage facility operated by the Gas del Caribe company within the Omoa city limits. The application alleges that the location of the storage facility on a geological fault line in an area that is vulnerable to natural disasters poses the danger of a chain explosion in the gas tanks. According to a study conducted by the Honduran public prosecution service, that situation could lead to the death of between 103 and 1,400 people, a risk that it described as “unacceptable.” The Commission asked the State to take the steps necessary to ensure the Gas del Caribe company’s effective observance of the environmental regulations and laws in place in Honduras, and to adopt the measures needed to reduce the danger to the lives and persons of the inhabitants of the community of Omoa to an acceptable level.

PM 423/10 – X, Argentina


On October 24, 2011, the IACHR granted precautionary measures in favor of X, in Argentina. His identity is being withheld because he is a minor. The application for precautionary measures alleged that the child has a developmental chronic encephalopathy and other diseases, and medical assistance provided by the State would have been inadequate, risking his lives and the development of his muscles and bones. The Commission requested the State to adopt urgent measures to ensure effective and the necessary medical attention so that the beneficiary can develop a quality life and dignity, in which he will not be affected beyond repair to his life, and to coordinate the measures with his family.

PM 305/11 – Wilmer Nahúm Fonseca and Family, Honduras


On October 13, 2011, the IACHR granted precautionary measures to Wilmer Nahúm Fonseca and his family, in Honduras. The precautionary measure request claims that six members of Wilmer Nahúm Fonseca’s family were disappeared during 2009 and 2010, allegedly by agents of the National Police. It also reports that his father, Apolonio Fonseca Mejía, was killed on June 27, 2011, and that his brother, Usai Fonseca Rodríguez, was the victim of an attempted homicide on October 3, 2011. The application indicates that the facts were reported to the authorities, but that no timely response was given. The Commission asked the State to take the steps necessary to ensure the lives and persons of Wilmer Nahúm Fonseca, Usai Fonseca Rodríguez, Lidia América Fonseca Rodríguez, Nolvia Suyapa Fonseca Rodríguez, Sarvia Thamar Fonseca Rodríguez, Milvia Sarai Fonseca Rodríguez, and the children of all the above. The Commission also asked the State to agree on the measures to be adopted with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 330/11 – José Reynaldo Cruz Palma, Honduras


On October 3, 2011, the IACHR granted precautionary measures on behalf of José Reynaldo Cruz Palma, in Honduras. The application for precautionary measures claims that José Reynaldo Cruz Palma, president of the Colonia Planeta employers’ association, in San Pedro Sula, disappeared on August 30, 2011, as he was traveling to Ciudad Planeta on a bus. In light of the alleged failure of the State to take actions to locate the suspected disappeared, the Commission asked the State to take the steps necessary to determine the situation and whereabouts of José Reynaldo Cruz Palma and to protect his life and person, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 153/11 – X and Z, Jamaica


On September 21, 2011, the IACHR granted precautionary measures to X and Z, in Jamaica. Their identities are being kept confidential at the request of the beneficiaries and/or their representatives. The request for precautionary measure states that both have suffered aggression, attacks, threats, and harassment on account of their sexual orientation. The Inter-American Commission asked the State of Jamaica to adopt the measures necessary to ensure their lives and persons, to agree on the steps to be taken with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of the precautionary measures.

PM 322/11 – Miriam Miranda, Honduras


On September 20, 2011, the IACHR granted precautionary measures on behalf of Miriam Miranda, in Honduras. The precautionary measure request claims that Miriam Miranda has suffered threats and harassment on account of her work defending the rights of Garifuna communities in Honduras. The Commission asked the State to take the steps necessary to ensure the life and person of Miriam Miranda, to agree on the measures to be adopted with the beneficiary and her representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 276/11 – X, Honduras


On September 15, 2011, the IACHR granted precautionary measures on behalf of X, in Honduras. X’s identity is being kept confidential since he is a minor. The request for precautionary measures alleges that on June 19, 2011, X and a friend were arrested by three Comayagüela police officers. It reports that the friend was released that same day, but when X’s family went to the police station to locate him, the officers gave them inconsistent information about his whereabouts. The Commission asked the State to take the steps necessary to determine X’s whereabouts and to ensure his life and person, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure. Later, the parties told the IACHR that a body had been found, presumably that of X. The IACHR asked the State to report on the formalities pursued to identify the body.

PM 240/11 – Eight members of the “Movimiento Autentico Reivindicador de Campesinos Aguan (MARCA) (Pedro Rigoberto Moran, Junior López, Julián Hernández, Antonio Francisco Rodríguez Velásquez, Santos Misael Cáceres Espinales, Eduardo Antonio Fuentes Rossel and Santos Eliseo Pavón Ávila), Honduras


On September 8, 2011, the IACHR granted precautionary measures to protect the lives and personal integrity of Pedro Rigoberto Moran, Junior López, Julián Hernández, Antonio Francisco Rodríguez Velásquez, Santos Misael Cáceres Espinales, Eduardo Antonio Fuentes Rossel and Santos Eliseo Pavón Ávila, all members of the “Movimiento Autentico Reivindicador de Campesinos Aguan” (MARCA) in Honduras. The request alleges that on August 20, 2011, Mr. Secundino Ruiz Vallecillos was murdered and Mr. Eliseo Pavón wounded. According to the party requesting the precautionary measures, the two men were on their way to the headquarters of the La Palma Cooperative when they were ambushed by hired gunmen, who allegedly shot them. It also alleged that the incident was part of a pattern of persecution of MARCA members. The Commission therefore asked the Honduran Government: 1) to take the measures necessary to protect the life and personal integrity of Pedro Rigoberto Moran, Junior López, Julián Hernández, Antonio Francisco Rodríguez Velásquez, Santos Misael Cáceres Espinales, Eduardo Antonio Fuentes Rossel and Santos Eliseo Pavón Ávila; 2) in concert with the beneficiaries and their representatives, to arrange the measures to be taken to taken; and 3) to report the measures taken to investigate the facts that necessitated the adoption of precautionary measures.

PM 301-11 − Manuel Valle, United States


On August 19, 2011, the IACHR granted precautionary measures for Manuel Valle, in the United States. The request for precautionary measure is accompanied by a petition alleging the violation of rights enshrined in the American Declaration, registered under the number P 1058-11. The Commission asked the United States to refrain from carrying out the death penalty until the IACHR had the opportunity to issue a decision on the petitioners' claims regarding the alleged violations of the American Declaration, in order not to render ineffective the processing of his claim before the inter-American system. Update: The death penalty against Manuel Valle was executed in a prison of the State of Florida on September 28, 2011.

PM 291/11 – José Antonio Cantoral Benavides y otros, Bolivia


On August 8, 2011, the IACHR granted precautionary measures on behalf of José Antonio Cantoral Benavides, a Peruvian national, who have refugee status in Bolivia. The Commission also received a petition referring to José Antonio Cantoral Benavides and others. The application for injunction alleged that Cantoral Benavides had been deprived of their liberty for August 1, 2011 and that during his detention would have been severely beaten. It also states that the August 3, 2011, the National Refugee Commission had issued a resolution which determines his immediate expulsion from the country, allegedly without having heard Cantoral Benavides and without complying with legal requirements. The Commission requested the State to adopt the necessary measures to refrain from expelling José Antonio Cantoral Benavides from Bolivia until the Commission rules on the merits of the petition, adopt the necessary measures to protect his life and personal integrity, and coordinate the measures to be adopted with the beneficiary and his representatives and report regularly to the Commission on actions taken. According to information received later, Mr. José Antonio Cantoral Benavides remains in Bolivia, under house arrest.

PM 199/11 – People deprived of their freedom at Professor Aníbal Bruno Prison, Brazil


On August 4, 2011, the IACHR granted precautionary measures on behalf of the people deprived of their freedom at Professor Aníbal Bruno Prison, in the city of Recife, state of Pernambuco, in Brazil. The precautionary measure request claims that 97 inmates of Professor Aníbal Bruno Prison have died since January 2008, with 55 of them meeting violent deaths. The request also alleges that several inmates have been tortured, reportedly by the authorities or with their consent. It further reports that there were two prison riots in July 2011, during which two people were killed and another 16 were injured. The Commission asked the State to adopt all the measures necessary to protect the lives, persons, and health of the inmates at Professor Aníbal Bruno Prison, to take the steps necessary to increase the number of security personnel at the facility, and to ensure that agents of the State’s security forces were responsible for internal security functions, eliminating the system of trusties known as “chaveiros” and relieving inmates of responsibility for disciplinary, oversight, and security functions. In addition, the IACHR asked the State to ensure adequate medical care was available to the beneficiaries and to report back on the steps taken, inter alia, to reduce overcrowding at this prison.

On October 2, 2012, the IACHR extended these precautionary measures to protect the employees and the visitors of this prison.

PM 160/11 – Kevin Cooper, United States


On August 3, 2011, the IACHR granted precautionary measures in favor of Kevin Cooper, who is detained in the United States pending the execution of the death penalty since 1986. The application for injunction was filed in the context of a communication on the alleged violation of rights enshrined in the American Declaration. Through the measures, the Commission asked the U.S. State to refrain from executing the death penalty pending the opportunity to decide on the petitioner's claim regarding the alleged violation of the American Declaration.

PM 368/10 – María Tirsa Paz and others, Colombia


On July 29, 2011, the IACHR granted precautionary measures on behalf of María Tirsa Paz and others, in Colombia. The request for precautionary measures alleges the existence of a situation of risk affecting 27 Afro-Colombian women and their families displaced from the municipalities of El Charco, Barbacoas, and La Tola in the department of Nariño. According to additional information provided by the applicants, the risks remain in place in the communities to which they relocated. In particular, they reported that in June 2011, in the neighborhood where four of the beneficiaries live, four youths were killed and another six were wounded in clashes between illegal groups. The Commission asked the State to take the steps necessary to ensure the lives and persons of the 27 displaced Afro-Colombian women and their families, to agree on the measures to be adopted with the beneficiaries and their representatives through talks, with due account taken of their particular situation, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 344/08 − Family of Javier Torres Cruz, Mexico


On July 19, 2011, the IACHR granted precautionary measures for the family of Javier Torres Cruz, in Mexico. Those requesting the precautionary measure allege that Javier Torres Cruz was killed on April 18, 2011, near his community of La Morena—located in the municipality of Petatlán, in the Mexican state of Guerrero—purportedly because of his activities to defend the right to a healthy environment in the Sierra de Petatlán. The request indicates that his family continues to be at risk following his murder, and that unidentified vehicles have been seen keeping the family home under surveillance. The petitioners noted that his brother Felipe Torres, who was with Javier Torres the day he was killed and was seriously wounded in the attack, had received a death threat. The Inter-American Commission asked the State of Mexico to take any necessary measures to guarantee the life and physical integrity of the family members of Javier Torres who live in the community of La Morena, located in Petatlán, Guerrero; to come to an agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 257/11 – Mark Anthony Stroman, United States


On July 18, 2011, the IACHR granted precautionary measures in favor of Mark Anthony Stroman, who is detained in the United States pending the execution of the death penalty since 2002. The application for injunction was filed in the context of a communication on the alleged violation of rights enshrined in the American Declaration. Through the measures, the Commission requested the State of the United States to refrain from executing the death penalty pending the opportunity to decide on the petitioner's claim regarding the alleged violation of the American Declaration. The Commission noted that the July 20, Mark Anthony Stroman was executed in Texas.

PM 218/11 − Yris Tamara Pérez Aguilera, Cuba


On July 6, 2011, the IACHR granted precautionary measures for Yris Tamara Pérez Aguilera, in Cuba. The request for precautionary measure alleges that Yris Tamara Pérez Aguilera, reportedly a leader of the Rosa Parks Feminist Movement and a political dissident, has been a victim of physical attacks, acts of harassment, and threats by agents of the State. It alleges specifically that as a result of a new attack she suffered on May 25, 2011, she is suffering from cervical trauma, memory loss, and headaches, and has not been provided with the medical treatment she needs. The Inter-American Commission asked the State of Cuba to adopt any necessary measures to guarantee the life and physical integrity of Yris Tamara Pérez Aguilera; to reach agreement with the beneficiary and her representatives on the measures to be adopted; and to inform the Commission about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 171-11 − Edwin A. Márquez González, United States


On July 5, 2011, the IACHR granted precautionary measures for Edwin A. Márquez González, in the United States. The request for precautionary measure alleges that Edwin Márquez González, a citizen of El Salvador facing a final deportation order, is in end-stage renal disease and receives hemodialysis treatment three times a week. It indicates that if Edwin Márquez González were to be deported, his life would be at risk, since the availability of hemodialysis treatment is limited in El Salvador. The Inter-American Commission asked the United States to urgently adopt any necessary measures to ensure that Edwin Márquez González is not deported until assurance is received that in El Salvador he will receive the medical treatment necessary to protect his right to life and physical integrity.

PM 349-06 − Humberto Leal García, United States


On July 1, 2011, the IACHR granted precautionary measures for Humberto Leal García, in the United States. The request for precautionary measure alleges that Humberto Leal García had not been granted a review of his case and that the state of Texas had scheduled his execution for July 7, 2011. The IACHR determined on July 24, 2008, that the State had violated Articles I, XVIII, and XXVI of the American Declaration of the Rights and Duties of Man against Leal García and other individuals, with regard to the criminal proceedings that led to the imposition of the death penalty. Consequently, the IACHR recommended that the United States stay the death sentence imposed on Leal García and the other victims in the case, and hold a new trial in accordance with the protections prescribed in the American Declaration. After it received information indicating that the execution had been scheduled, the Inter-American Commission asked the United States to suspend it. Update: Humberto Leal García was executed on July 7, 2011.

PM 359/10 – Members of Justice and Dignity Corporation, Colombia


On June 28, 2011, the IACHR granted precautionary measures on behalf of members of Justice and Dignity Corporation, in Colombia. The request for precautionary measures claims that over recent months, there has been a worsening in the threats, harassment, and tailing to which they have been subjected, on account of which they were forced to relocate from Santiago de Cali. It also notes that the authorities have been informed of the situation but have provided no security measures to counter the risk. The Commission asked the State to take the steps necessary to ensure the lives and persons of Alexander Montaña, Sofía López, Walter Mondragón Delgado, and Homero Montaña, to agree on the measures to be adopted with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 448/10 – Víctor Ayala Tapia, Mexico


On June 28, 2011, the IACHR granted precautionary measures on behalf of Víctor Ayala Tapia, in Mexico. The request for precautionary measures claims that Víctor Ayala Tapia disappeared on September 14, 2010, when heavily armed individuals broke into his home, threatened the people present with their weapons, and proceeded to abduct Mr. Ayala Tapia. In light of the alleged failure to take actions to locate the suspected disappearee, the Commission asked the State to take the steps necessary to determine the situation and whereabouts of Víctor Ayala Tapia and to protect his life and person, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 219-11—Relatives of Inmates at the Rodeo I and Rodeo II Prisons, Venezuela


On June 21, 2011, the IACHR granted precautionary measures for relatives of the inmates at the Rodeo I and Rodeo II prisons in Venezuela, as well as for protesters and others who have crowded into the area around the facilities. The request for precautionary measures indicates that relatives of the inmates reportedly went to the area surrounding the Rodeo I and II facilities to ask for information about the prisoners' situation, following an operation carried out by the authorities to regain control of the prisons. The information provided by the petitioners indicates that the security forces launched tear gas canisters and used water cannons against them, in a context of tension. The Inter-American Commission asked the State of Venezuela to guarantee the life and physical integrity of the relatives of the inmates at the Rodeo I and II prisons, as well as others who are in the immediate vicinity of the correctional facilities, until the situation returns to normal.

PM 185/10 — X, Ecuador


On June 20, 2011, the IACHR granted precautionary measures in favor of X in Ecuador in order to protect his life and personal integrity. This precautionary measure is being withheld of publication at the request of the beneficiary and his representatives.

PM 121-11 − 14 Q'echi Indigenous Communities of the Municipality of Panzós, Guatemala


On June 20, 2011, the IACHR granted precautionary measures for 14 Q'echi indigenous communities of the municipality of Panzós, in Guatemala. The request for precautionary measure alleges that 14 Q'echi indigenous communities were forcibly evicted in the municipality of Panzós, in Guatemala's department of Alta Verapaz, between March 15 and 23 of 2011. It alleges that the court eviction order had not been communicated to the affected communities and was not carried out in compliance with the law. The information the Commission has received indicates that, more than two months following the eviction, between 700 and 800 families from the community are living in precarious conditions, without access to food and water, and that State agencies have failed to provide them with shelter or nutrition solutions. It is also indicated that acts of violence were perpetrated against the communities on May 13 and 21 and June 4, which reportedly led to the deaths of two individuals. The Inter-American Commission requested that the State of Guatemala adopt any necessary measures to guarantee the life and physical integrity of the members of the 14 Q'echi indigenous communities; adopt any necessary measures to provide humanitarian assistance, including food and shelter, to the members of the 14 displaced communities; and come to an agreement with the beneficiaries and their representatives on the measures to be adopted.

PM 150/11 – Sandra Viviana Cuéllar, Colombia


On June 22, 2011, the IACHR granted precautionary measures in favor of Hildebrando Vélez. According to the information received, Hildebrando Vélez has received threats on account of his involvement in the search for Sandra Viviana Cuéllar. The Commission asked the State to take the necessary steps to protect the life and personal integrity of Hildebrando Vélez, to agree on the measures to be adopted with the beneficiary and his representative, and to report back on the actions carried out to investigate the facts that gave rise to the precautionary measure. On June 22, 2011, the IACHR expanded this precautionary measure to cover Sandra Viviana Cuéllar, in Colombia. The precautionary measure request reports that Sandra Viviana Cuéllar is disappeared and that her alleged disappearance was a consequence of her environmental protection work in Valle del Cauca. Given the seriousness and urgency of the alleged facts and the lack of information on the whereabouts of the suspected disappeared, the IACHR granted precautionary measures to ensure the beneficiary’s life and person. The Commission asked the State for the immediate adoption of the measures necessary to determine the situation and whereabouts of Sandra Viviana Cuéllar and to protect her life and person, and it requested that the State report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 281/10 – Oscar Siri Zuñiga and Family, Honduras


On June 10, 2011, the IACHR granted precautionary measures on behalf of Oscar Siri Zuñiga and his family, in Honduras. The precautionary measure request alleges that since February 2011, armed individuals have been monitoring Siri Zuñiga’s home, and that on May 19 an exchange of gunfire took place on his property when three armed individuals attempted to enter his home. It adds that the security detail provided by the State has been reduced to one person. The Commission asked the State to take the steps necessary to ensure the lives and persons of Oscar Siri Zuñiga and his family, to agree on the measures to be adopted with the beneficiaries and their representatives and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 187/11 – Idania Yanes Contreras and Family, Cuba


On June 8, 2011, the IACHR granted precautionary measures on behalf of Idania Yanes Contreras and her family, in Cuba. The request for precautionary measures claims that Idania Yanes Contreras has suffered acts of intimidation and physical attacks at the hands of the security forces, allegedly because of her involvement in protest demonstrations over recent years. It also reports that on April 8, 2011, she was beaten by security officials of the State, an incident that left her in a delicate state of health. The Inter-American Commission asked the State of Cuba to adopt the measures necessary to ensure the life and person of Idania Yanes Contreras and those of the members of her family, to agree on the steps to be taken with the beneficiary and her representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of precautionary measures.

PM 355/10 − 21 Families of the Nonam Community of the Wounaan Indigenous People, Colombia


On June 3, 2011, the IACHR granted precautionary measures for 21 families of the Nonam community of the Wounaan indigenous people, in Colombia. The request for precautionary measure alleges that the families have been subject to acts of harassment on the part of the armed forces and illegal armed groups. It indicates that they were forced to move from their territory, and as a result have had serious problems with access to food, housing, and medicine. It also alleges that the families have not received consistent and effective medical and humanitarian care in the nine months since they were displaced, even though a protection order was issued in their favor. This situation allegedly led to the death of an 11-month-old girl from tuberculosis, on May 12, 2011. The Inter-American Commission asked the State of Colombia to adopt necessary measures, agreed upon with the beneficiaries, to guarantee the life and physical integrity of the 21 families of the Wounaan indigenous community; provide humanitarian assistance and medical care to the beneficiaries in a situation of displacement; and guarantee their return to the Guayacán Santa Rosa Indigenous Reserve in conditions of dignity and security.

PM 5/11 — Haitian Nationals in Process of Deportation, United States (AMPLIFICATION)


On May 31, 2011, the IACHR expanded Precautionary Measure 5/11 in favor of 33 persons facing deportation from the United States to Haiti. The identity of the beneficiaries will be kept under seal at the request of the applicants. The request for precautionary measure alleges that the lives and health of these individuals could be at grave risk if they were to be deported to Haiti, given their health conditions and the lack of relatives in Haiti to assist them in obtaining access to medical treatment, food and drinking water. The Inter-American Commission asked that the United States suspend the deportation process in the case of the 33 additional beneficiaries until such time as: (1) Haiti is able to guarantee that detention conditions and access to medical care for persons in custody comply with applicable minimum standards, and (2) the procedures in place to decide upon and review the deportation of the 33 beneficiaries adequately take into account their right to family life and their family ties in the United States. The IACHR also requested the United States to inform the Commission as to the actions taken in cooperation with the beneficiaries and the petitioners to implement these measures.

(The PM 5/11 was granted February 1, 2011; since them, the IACHR approved several amplifications. Read full summary below).

PM 55/10 – Patricia Galarza Gándara and others, Mexico


On May 19 2011, the IACHR granted precautionary measures on behalf of Patricia Galarza Gándara, Oscar Enríquez, Javier Ávila, and Francisca Galván, in Mexico. The request for precautionary measures claims that these individuals are the legal representatives of the families of Rocío Irene Alvarado Reyes, Nitza Paola Alvarado Espinoza, and José Angel Alvarado Herrera, all of whom disappeared in December 2009. Several relatives and one representative of the disappeared are covered by provisional measures issued by the Inter-American Court. The application states that the beneficiaries have suffered acts of intimidation. The Commission asked the State to take the steps necessary to ensure the lives and persons of Patricia Galarza Gándara, Oscar Enríquez, Javier Ávila, and Francisca Galván, to agree on the measures to be adopted with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 111/10 − Rosa Díaz Gómez and Other Members of the Jotolá Ejido, Mexico


On May 19, 2011, the IACHR granted precautionary measures for Rosa Díaz Gómez and other members of the Jotolá ejido, in Mexico. The request for precautionary measure indicates that Rosa Díaz Gómez and other members of the Jotolá ejido had been subject to attacks and threats by individuals since March 24, 2010. It alleges that the measures adopted by the government were not effective, and that the situation of risk had increased with the release on bail of the alleged attackers in April 2011. The Inter-American Commission asked the State of Mexico to adopt any necessary measures to guarantee the life and physical integrity of Rosa Díaz Gómez, Carmela Sánchez Cruz, César Augusto Sánchez Gómez, Anita Méndez Aguilar, Marcos Moreno Méndez, Francisco Moreno Méndez, Enriqueta Gómez Santis, Maikon Pakal Sánchez Gómez, Sami Santiago Sánchez Gómez, Ricardo Sánchez Luna, Mario Sánchez López, Marcelina Arco Pérez, Débora Sánchez Arco, Marcela Sánchez Arco, Mario Sánchez Arco, Isaías Sánchez Arco, Hilaria Pérez Jiménez, Mario Josué Sánchez Pérez, and Saraí Sánchez Pérez, and that it reach agreement with the beneficiaries and their representatives on the measures to be adopted.

PM 270/10 – Nazareth Migrant House and Human Rights Center, Nuevo Laredo, Mexico


On May 16, 2011, the IACHR granted precautionary measures on behalf of the members of Nazareth Migrant House and of the Human Rights Center of Nuevo Laredo, in Mexico. The request for precautionary measures claims that the members of Nazareth Migrant House and the Human Rights Center of Nuevo Laredo, in the state of Tamaulipas, have been followed and threatened. The Commission asked the State to take the steps necessary to ensure the lives and persons of the members of Nazareth Migrant House and the Human Rights Center of Nuevo Laredo, to agree on the measures to be adopted with the beneficiaries and their representatives, and to report back on the actions carried out to investigate the facts that gave rise to the adoption of this precautionary measure.

PM 143/11 − Leo Valladares Lanza and Daysi Pineda Madrid, Honduras


On April 26, 2011, the IACHR granted precautionary measures for Leo Valladares Lanza and Daysi Pineda Madrid, in Honduras. The request for precautionary measure indicates that Leo Valladares Lanza and his wife, Daysi Pineda Madrid, have been followed and subjected to acts of harassment by unknown individuals, following comments Valladares Lanza made on a television program in February 2011. It adds that on March 28, 2011, unknown individuals entered the offices of the Asociación por una Ciudadanía Participativa (Association for a Participatory Citizenship), of which Valladares Lanza is executive director, and went through the organization's documents. The request alleges that even though the petitioners had filed a complaint and a request for protection, the State had not adopted measures to ensure their security. The Inter-American Commission asked the State of Honduras to take the necessary measures to guarantee the life and physical integrity of Leo Valladares Lanza and Daysi Pineda Madrid; to ensure that Leo Valladares Lanza can continue his work of promoting and defending human rights under safe conditions; and to reach agreement with the beneficiaries and their representatives on the measures to be adopted.

PM 404/10 − Qom Navogoh Indigenous Community of "La Primavera," Argentina


On April 21, 2011, the IACHR granted precautionary measures for the members of the Qom Navogoh indigenous community of "La Primavera," in the province of Formosa, Argentina. The request for precautionary measures alleges that members of the security forces had perpetrated a series of acts of violence against members of the community and that as a result, leader Félix Díaz and his family were forced to move to another region. The petitioners reported that the attackers were continuing to guard the area, creating a climate of tension among area residents. They also added that security measures that would allow the return of Félix Díaz and his family had not been implemented. The Inter-American Commission asked the State of Argentina to adopt any necessary measures to guarantee the life and physical integrity of the members of the Qom Navogoh indigenous community of "La Primavera" against possible threats, attacks, or acts of harassment on the part of members of the police, law enforcement officers, or other State agents, as well as to implement any necessary measures so that Félix Díaz and his family can return to the community under safe conditions.

PM 115/11 − Journalists at La Voz de Zacate Grande, Honduras


On April 18, 2011, the IACHR granted precautionary measures for the journalists at La Voz de Zacata Grande in Honduras. The request for precautionary measures indicates that since the radio station La Voz de Zacate Grande opened in April 2010, its journalists had been subject to acts of harassment and aggression on the part of private individuals and members of the State security forces. It alleges that on March 13, 2011, Franklin Meléndez was attacked with a firearm by alleged opponents of the radio station's editorial stance, and that other journalists from the station had then been subject to threats. The request alleges that the authorities had not investigated the incidents with due diligence. The Inter-American Commission requested that the State of Honduras adopt the necessary measures to guarantee the life and safety of the journalists at La Voz de Zacate Grande, and that it come to an agreement with the beneficiaries and their representatives on the measures to be adopted.

PM 269/08 − Members of the Lof Paichil Antriao Community of the Mapuche Indigenous People, Argentina 


On April 6, 2011, the IACHR granted precautionary measures for the members of the Lof Paichil Antriao community of the Mapuche indigenous people. The request for precautionary measure alleges that there is a grave and urgent situation involving risk of irreparable harm stemming from acts of harassment; that there is a risk that a sacred place known as a Rewe will be destroyed; that access by members of the Lof Paichil Antriao community to the Rewe is being obstructed; and that families of the community have been displaced from territory they claim as their ancestral land. The request also alleges that while the Rewe is currently being protected by a domestic legal measure, the members of the community have not been able to gain access to the site to practice the rituals called for by their culture. It also indicates that the families that are displaced in areas adjacent to the disputed territory are facing a precarious situation with regard to health and food. The Inter-American Commission asked the State of Argentina to adopt the necessary measures to guarantee that the protective legal measure to prevent alteration of the Rewe located on the property that is the object of the litigation is not lifted until the IACHR has ruled on the merits of Petition 962-08, currently being examined. On this matter, the Commission also requested that the State adopt measures to ensure effective compliance with the aforementioned legal measure so that this sacred place is preserved. In addition, the IACHR asked the State to take the necessary steps to guarantee that members of the Lof Paichil Antriao community who need to access the Rewe to practice their rituals may do so, without police forces or other public or private security or surveillance groups hindering their access or their stay for whatever time they wish, and without episodes of violence, attacks, harassment, or threats on the part of the police of other security groups. Finally, the Commission requested that the State adopt the necessary measures to look after the health of the community families that are displaced in areas adjacent to the disputed territory, in order to guarantee their well-being.

PM 105/11 − Communities of the Kuna of Madungandí and Emberá of Bayano Peoples, Panama


On April 5, 2011, the IACHR granted precautionary measures for the Kuna of Madungandí and Emberá of Bayano peoples, in Panama. This precautionary measure is connected with Case 12.354, which is being processed by the IACHR and is now in the merits phase. (Admissibility Report No. 58/09 was approved on April 21, 2009.) The request for precautionary measure alleges that in February and March of 2011 there were massive intrusions into the territories of the Kuna of Madungandí and Emberá of Bayano indigenous reserve. It alleges that colonists violently seized and destroyed virgin forests that would have been used by the indigenous communities to ensure their food supply. The petitioners noted that this has been a recurring situation and alleged that the State is not adopting diligent measures to stop such invasions. In order to ensure that the subject of the petition in this case does not become moot, the Commission requested that the State of Panama adopt any necessary measures to protect the ancestral territory of the communities of the Kuna of Madungandí and Emberá of Bayano peoples from intrusions by third parties and from the destruction of their forests and crops, until such time as the IACHR has adopted a final decision in Case 12.354.

PM 87/11 − Blanca Estela Puac Menchú and Family, Guatemala


On April 4, 2011, the IACHR granted precautionary measures for Blanca Estela Puac Menchú and her family, in Guatemala. The request for precautionary measures alleges that Mrs. Blanca Estela Puac Menchú and her daughter were victims of an attack on February 12, 2011, which reportedly resulted in the death of agent William Estuardo Orozco Pineda and the wounding of agent Heberto Revolorio, both of whom were fulfilling their duty to protect her. The Inter-American Commission requested that the State of Guatemala adopt the necessary measures to guarantee the life and physical integrity of the beneficiaries, that it reach agreement with the beneficiaries and their representative on the measures to be adopted, and that it inform the IACHR on the steps taken to investigate the facts that led to the adoption of these precautionary measures.

PM 72/11 − Leonel Casco Gutiérrez, Honduras


On April 4, 2011, the IACHR granted precautionary measures for Leonel Casco Gutiérrez, in Honduras. The request for precautionary measures alleges that Leonel Casco Gutiérrez, Director of the legal area of the Ecumenical Human Rights Observatory in Honduras, is in a situation of risk due to his involvement in a series of public denunciations regarding an alleged plan to murder certain individuals in Honduras. In addition, the petitioner indicates that he and his wife have received threats via telephone messages. The Inter-American Commission asked the State of Honduras to adopt the necessary measures to guarantee the life and physical integrity of the beneficiary, and to come to an agreement with him on the measures to be adopted.

PM 382/10 - Indigenous Communities of the Xingu River Basin, Pará, Brazil&


On April 1, 2011, the IACHR granted precautionary measures for the members of the indigenous communities of the Xingu River Basin in Pará, Brazil: the Arara of Volta Grande do Xingu; the Juruna of Paquiçamba; the Juruna of "Kilómetro 17"; the Xikrin of Trincheira Bacajá; the Asurini of Koatinemo; the Kararaô and Kayapó of the Kararaô indigenous lands; the Parakanã of Apyterewa; the Araweté of the Igarapé Ipixuna; the Arara of the Arara indigenous lands;  the Arara of Cachoeira Seca; and the Xingu Basin indigenous communities in voluntary isolation. The request for precautionary measure alleges that the life and physical integrity of the beneficiaries is at risk due to the impact of the construction of the Belo Monte hydroelectric power plant. The Inter-American Commission requested that the State of Brazil immediately suspend the licensing process for the Belo Monte Hydroelectric Plant project and stop any construction work from moving forward until certain minimum conditions are met. The State must (1) conduct consultation processes, in fulfillment of its international obligations—meaning  prior consultations that are free, informed, of good faith, culturally appropriate, and with the aim of reaching an agreement—in relation to each of the affected indigenous communities that are beneficiaries of these precautionary measures; (2) guarantee that, in order for this to be an informed consultation process, the indigenous communities have access beforehand to the project's Social and Environmental Impact Study, in an accessible format, including translation into the respective indigenous languages; (3) adopt measures to protect the life and physical integrity of the members of the indigenous peoples in voluntary isolation of the Xingu Basin, and to prevent the spread of diseases and epidemics among the indigenous communities being granted the precautionary measures as a consequence of the construction of the Belo Monte hydropower plant. This includes any diseases derived from the massive influx of people into the region as well as the exacerbation of transmission vectors of water-related diseases such as malaria.

On July 29, 2011, during its 142nd regular session, the IACHR evaluated Precautionary Measure 382/10, based on information submitted by the State and the petitioners, and modified the aim of the measure. The IACHR requested that the State: 1) Adopt measures to protect the lives, health, and physical integrity of the members of the Xingu Basin indigenous communities in voluntary isolation and to protect the cultural integrity of those communities, including effective actions to implement and execute the legal/formal measures that already exist, as well as to design and implement specific measures to mitigate the effects the construction of the Belo Monte dam will have on the territory and life of these communities in isolation; 2) Adopt measures to protect the health of the members of the Xingu Basin indigenous communities affected by the Belo Monte project, including (a) accelerating the finalization and implementation of the Integrated Program on Indigenous Health for the UHE Belo Monte region, and (b) designing and effectively implementing the recently stated plans and programs that had been specifically ordered by the FUNAI in Technical Opinion 21/09; and 3) Guarantee that the processes still pending to regularize the ancestral lands of the Xingu Basin indigenous peoples will be finalized soon, and adopt effective measures to protect those ancestral lands against intrusion and occupation by non-indigenous people and against the exploitation or deterioration of their natural resources. Moreover, the IACHR decided that the debate between the parties on prior consultation and informed consent with regard to the Belo Monte project has turned into a discussion on the merits of the matter, which goes beyond the scope of precautionary measures.

PM 80/11 - Maurice Tomlinson, Jamaica


On March 21, 2011, the IACHR granted precautionary measures for Maurice Tomlinson, in Jamaica. The request for precautionary measures alleges that Maurice Tomlinson is facing a situation of risk due to his work as a defender of the rights of lesbian, gay, bisexual, trans, and intersex (LGBTI) persons in Jamaica. It indicates that he has been receiving death threats via e-mail, and that the State authorities have not adopted protection measures. The Inter-American Commission asked the State of Jamaica to adopt, in agreement with the beneficiary, the necessary measures to guarantee his life and physical integrity, and to inform the IACHR on the steps taken to investigate the facts that led to the adoption of these precautionary measures.

PM 61/11 − Members of the Awá Indigenous People of the Departments of Nariño and Putumayo, Colombia


On March 16, 2011, the IACHR granted precautionary measures for the members of the Awá indigenous people of the departments of Nariño and Putumayo, Colombia. According to the request for precautionary measure and information from various sources, the Awá people have been the target of numerous attacks, murders, and threats in the context of the armed conflict in Colombia. The information indicates that clashes between the Army and irregular armed groups have taken place recently in territory of the Chinguirito Mira indigenous reserve and of the community of La Hondita, leaving members of the Awá people caught in the middle of the crossfire. The request indicates, moreover, that in 2011 three accidents have reportedly taken place involving antipersonnel landmines planted in Awá ancestral territory by participants in the armed conflict. The Inter-American Commission requested that the State of Colombia adopt measures, agreed upon with the beneficiaries, to guarantee the life and physical integrity of the members of the Awá indigenous people of the departments of Nariño and Putumayo, including landmine removal their ancestral territory and landmine risk education for the members of the Awá people.

PM 62/11 − Félix Rocha Díaz, United States


On March 10, 2011, the IACHR granted precautionary measures for Félix Rocha Díaz. The precautionary measures are accompanied by a petition concerning the alleged violation of Articles I, XVIII, XXV, and XXVI of the American Declaration, which is being processed under No. P 259-11. The request for precautionary measure alleges that there had been errors in Félix Rocha Díaz's legal representation at trial, and that the 13 years he has spent on death row constitutes cruel and unusual punishment. The Commission asked the United States to refrain from carrying out the death penalty until the Commission has the chance to rule on the petitioner's claim regarding the alleged violation of the American Declaration, so as not to render ineffective the processing of the claim in the inter-American human rights system.

PM 57/11 − Pedro Vicente Elvir and Dagoberto Posadas, Honduras


On March 9, 2011, the IACHR granted precautionary measures for Pedro Vicente Elvir and Dagoberto Posadas, in Honduras. The request for precautionary measures alleges that Pedro Vicente Elvir and Dagoberto Posadas, President and Director of the Communication Unit of the National Child Protection Workers Union (Sindicato de Trabajadores del Patrono Nacional de la Infancia, SITRAPANI), are in a situation of risk due to their work in the union. They are reported to have been victims of acts of violence in which their assailants used guns to frighten them. The Inter-American Commission asked the State of Honduras to adopt the necessary measures to guarantee the life and physical integrity of the beneficiaries, and to reach agreement with the beneficiaries and their representatives on the measures to be adopted.

PM 50/11 − Jimena Castillo et al., Honduras


On March 3, 2011, the IACHR granted precautionary measures for Jimena Castillo Canales, Lorena Ruiz, Berta Haydee Canales Alvarado, Gabriela Castillo Morales, and Ana Belia Morales Rivera, in Honduras. The request for precautionary measures alleges that on February 13, 2011, Jimena Castillo Canales and Lorena Ruiz were traveling in a vehicle when two masked individuals reportedly shot at them 15 times. Jimena Castillo was wounded in the arm, and eight bullets hit the vehicle. The Inter-American Commission asked the State of Honduras to adopt the necessary measures to guarantee the beneficiaries' life and physical integrity and to reach agreement with the beneficiaries and their representatives on the measures to be adopted.

PM 321/10 - Rapa Nui Indigenous People, Chile 


On February 7, 2011, the IACHR granted precautionary measures for the Rapa Nui Indigenous People of Easter Island, Chile. The request for precautionary measure alleges that the Rapa Nui people's life and integrity are at risk due to acts of violence and intimidation reportedly carried out by police in the context of demonstrations and evictions. The Inter-American Commission asked the State of Chile to immediately bring an end to the use of armed violence in the execution of State administrative or judicial actions against members of the Rapa Nui people, including evictions from public spaces or from public or private property; to guarantee that the actions of State agents in the framework of protests and evictions do not jeopardize the life or physical integrity of the members of the Rapa Nui people; to inform the IACHR within 10 days about the adoption of these precautionary measures; and to update this information periodically. On October 31, 2011, the IACHR lifted the precautionary measure and archived the file.

PM 5/11 — Gary Resil, Harry Mocombe, Roland Joseph, Evel Camelien, and Pierre Louis, United States


On February 1, 2011, the IACHR granted precautionary measures for Gary Resil, Harry Mocombe, Roland Joseph, Evel Camelien, and Pierre Louis, in the United States. The request for precautionary measure alleges that the lives and health of these individuals could be at grave risk if they were to be deported to Haiti, given that once they arrived in the country they would probably remain in custody, without access to food, drinking water, and adequate medical treatment. It also indicates that these individuals have their immediate families in the United States and that most of their family members in Haiti had died in the January 2010 earthquake. The Inter-American Commission asked that the United States suspend the deportation process in the case of the five beneficiaries until such time as: (1) Haiti is able to guarantee that detention conditions and access to medical care for persons in custody comply with applicable minimum standards, and (2) the procedures in place to decide upon and review the deportation of the five beneficiaries adequately take into account their right to family life and their family ties in the United States.

On May 31, 2011, the IACHR expanded Precautionary Measure 5/11 in favor of 33 persons facing deportation from the United States to Haiti. The identity of the beneficiaries will be kept under seal at the request of the applicants. The request for precautionary measure alleges that the lives and health of these individuals could be at grave risk if they were to be deported to Haiti, given their health conditions and the lack of relatives in Haiti to assist them in obtaining access to medical treatment, food and drinking water. The Inter-American Commission asked that the United States suspend the deportation process in the case of the 33 additional beneficiaries until such time as: (1) Haiti is able to guarantee that detention conditions and access to medical care for persons in custody comply with applicable minimum standards, and (2) the procedures in place to decide upon and review the deportation of the 33 beneficiaries adequately take into account their right to family life and their family ties in the United States. The IACHR also requested the United States to inform the Commission as to the actions taken in cooperation with the beneficiaries and the petitioners to implement these measures.

On June 27, 2011 the IACH extended this precautionary measure to protect two additional persons who requested their identity to be kept confidential.

On September 29, 2011 the IACHR extended this precautionary measure to protect Louis Raphael.

On June 5, 2012, the IACHR extended this precautionary measure to protect eight additional persons who requested their identity to be kept confidential.

PM 13/11 - Néstor Rodríguez Lobaina and Family, Cuba


On January 24, 2011, the IACHR granted precautionary measures for Néstor Rodríguez Lobaina and his family, in Cuba. The request for precautionary measure alleges that on December 9, 2010, Néstor Rodríguez Lobaina was out walking with his 10-year-old daughter, Diana Rodríguez Castillo, when he was intercepted by agents of the political police. According to the request, the agents reportedly hit him with pepper spray and put him in a patrol car, leaving the girl by herself, 15 blocks away from home. The request adds that after being detained for 72 hours at the Department for State Security Operations in the city of Guantánamo, he was apparently transferred on December 12 to the Guantánamo Provincial Prison and that his family has not received any information about his state of health or about any treatment he may or may not be receiving for burns he allegedly suffered as a result of the pepper spray having hit him at close range. The Inter-American Commission asked the State of Cuba to adopt any necessary measures to preserve and guarantee the life and physical integrity of Néstor Rodríguez Lobaina and his family, and to allow access and health treatment and monitoring by a doctor trusted by him or by an international organization.

PM 199/09 − 300 Inhabitants of Puerto Nuevo, Peru 

On December 27, 2010, the IACHR called for the adoption of precautionary measures to protect the life and personal integrity of 300 inhabitants of Puerto Nuevo Callao in Peru. According to the information furnished, activities involving the warehousing and transport of lead have seriously compromised the health of 300 inhabitants of the Puerto Nuevo human settlement, and have high levels of that substance in their blood. It is alleged that the lead poisoning victims lack the appropriate medical care in terms of diagnosis, treatment, and prevention of illness. Moreover, it has been noted that the actions undertaken by the State to protect the inhabitants of Puerto Nuevo from the effects of lead poisoning have not been effective in reducing their risk of exposure. Consequently, the Commission required the Peruvian State to adopt the necessary measures with a view to suspending lead warehousing and transport activities in Puerto de Callao until such time as it is able to adopt, inter alia, measures to effectively eliminate the situation of environmental contamination, relocate the population, or provide for an alternative lead warehousing site; to adopt the necessary measures to provide specialized medical diagnostic services for the beneficiaries as well as appropriate and specialized medical treatment to those whose diagnosis indicates a risk of irreparable harm to their personal integrity or life; and to continue adopting the necessary measures to mitigate harm to the environment.

PM 340/10 − Women and girls residing in 22 Camps for internally displaced persons in Port-au-Prince, Haiti 

On December 22, 2010, the IACHR granted precautionary measures for all the displaced women and children living in 22 camps for internally displaced persons in Port-au-Prince, Haiti, in the wake of the January 10, 2010 earthquake. The request for precautionary measures alleges a pattern of sexual violence and a series of acts of violence against the women and girls residing in said camps. The Inter-American Commission called on the State to ensure the availability of adequate medical and mental health care for the victims of sexual violence located in accessible areas; to provide adequate security at the camps for internally displaced persons, including the lighting of public spaces, regular patrols within the camps as well as outlying areas, and to increase the presence of female police officers assigned to patrol details and local police precincts; to ensure that the law enforcement agencies tasked with responding to incidents of sexual violence receive the necessary training to respond appropriately to reported cases of sexual violence and provide the necessary security to the camps; to promote the establishment of special investigative police units within the Office of the Attorney General with a view to investigating rape cases and other crimes of sexual violence; and to ensure that grassroots women’s groups fully participate in and have a steering role in the planning and implementation of policies and practices aimed at combating and preventing rape and other forms of sexual violence in the camps.

PM 410/10 − Héctor Francisco Lucas Méndez, Guatemala 

On December 13, 2010, the Commission requested precautionary measures on behalf of Héctor Francisco Lucas Méndez. According to the information furnished, the beneficiary would be in a situation of risk, presumably due to the opening of proceedings that would result in investigations and trials in the alleged murder of his brother, Junio Maynor Lucas Méndez, which allegedly occurred on August 17, 2010. Specifically, the requesters noted that Mr. Héctor Francisco Lucas Méndez had suffered an attack on his life on September 28, 2010, one day after he had given his statement in the aforementioned legal proceeding. In view of the foregoing, the IACHR requested, inter alia, that the State adopt the necessary measures to protect the life and physical integrity of Héctor Francisco Lucas Méndez, and to investigate the events leading to the adoption of the precautionary measures.

PM 383/10 - John Jairo Palacios, Colombia

On November 23, 2010, the IACHR granted precautionary measures for John Jairo Palacios, in Colombia. The request for precautionary measures alleges that on July 30, 2010, John Jairo Palacios was a victim of forced disappearance, which had reportedly been carried out by paramilitary groups. The IACHR requested information from the State based on its authority under Article XIV of the Inter-American Convention on Forced Disappearance of Persons, but it did not receive information that would clarify his whereabouts. In view of the seriousness and urgency of the allegations and the lack of information on the whereabouts of the allegedly disappeared person, the IACHR granted precautionary measures so as to guarantee the life and humane treatment of John Jairo Palacios. The Commission requested that the State provide information on the whereabouts of John Jairo Palacios, his state of health, and his security situation; that it adopt the necessary measures to ensure the life and physical integrity of John Jairo Palacios; and that it report on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 367-10 - Forced Evictions from Five Camps for Displaced Persons, Haiti

On November 15, 2010, the IACHR granted precautionary measures for the residents of five camps for internally displaced persons in Haiti. The request for precautionary measures alleges that forced evictions were carried out in five encampments created by families that set up tents in open fields, on public or private property, following the destruction of their homes by the earthquake. The Inter-American Commission asked the State of Haiti to adopt a moratorium on the expulsions from the camps for internally displaced persons until a new government can take office; to ensure that those who have been illegally expelled from the camps are transferred to places with minimum sanitary and security conditions; to guarantee that those who have been internally displaced have access to effective remedies in court and before other competent authorities; to implement effective security measures to safeguard the physical integrity of the camps' inhabitants, guaranteeing in particular the protection of women and children; to train security forces on the rights of displaced persons, in particular their right not to be expelled from the camps by force; and to ensure that international cooperation agencies have access to the camps for internally displaced persons.

PM 192-10 - LM, Paraguay

On November 10, 2010, the IACHR granted precautionary measures for LM, in Paraguay. The request for precautionary measures alleges that due to a series of legal proceedings to determine who was responsible for the care and custody of the child LM, his alleged biological relatives had not been able to have access to him. According to the last communications submitted by the petitioners, the Commission understands that the situation continues to this day with no decision that would determine the child's situation, which could lead to his rights being affected in a series of ways. Based on the principle of the best interests of the child, the IACHR granted precautionary measures so as to ensure that the time factor does not become a determining element for the domestic courts, to the detriment of LM's rights. Within this framework, the IACHR asked the State to take the necessary measures to ensure that the proceedings related to the guardianship and custody of the child LM are resolved within a period of three months, and to report on the steps taken to comply with this precautionary measure.

PM 92-10 - Juan Manuel Martínez and Family, Mexico

On November 4, 2010, the IACHR granted precautionary measures for Juan Manuel Martínez Moreno and his family, in Mexico. The request for precautionary measures alleges that Juan Manuel Martínez and his family were the object of threats, were followed, and were subject to acts of harassment since the beginning of 2010, when Juan Manuel Martínez was released from prison. According to information provided by the petitioners, Juan Manuel Martínez was arrested in 2008 for acts connected with the death of U.S. videographer Bradley Roland Will of Indymedia, who was shot to death on October 27, 2006, in Oaxaca. The request indicates that the wife of Juan Manuel Martínez received an intimidating phone call on January 18, 2010, in which she was instructed to stop denouncing the alleged injustices committed against her husband and told that if she failed to do so, the lives of her three children would be at risk. From that point on, the family was reportedly the object of other threats, had been followed by automobiles with no tags and with tinted windows, and had had its residence under surveillance by individuals taking photographs and notes, among other things. The Inter-American Commission asked the State of Mexico to take the necessary steps to guarantee the life and integrity of Juan Manuel Martínez and his family; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to report on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 395-09 – Maho Indigenous Community, Suriname

On October 27, 2010, the IACHR granted precautionary measures for the inhabitants of the Maho Indigenous Community, in Suriname. The request for precautionary measures alleges that since 1990, the organization Stichtung Mohsiro and other third parties have allegedly been encroaching upon the 65 hectares of land that was reserved for the Maho Community in 1971. It is also alleged that at times, the invaders have destroyed the community’s crops and threatened its members’ physical integrity. It is alleged that as a result of these actions, the extinction of this community may be imminent. The Inter-American Commission asked the State of Suriname to take the measures necessary to ensure that the Maho Community can survive on the 65 hectares that have been reserved for it free from incursions from persons alien to the community, until the Commission has decided on the merits of the petition.

PM 197-10 - 135 Inhabitants of San Juan Copala, Mexico

On October 7, 2010, the IACHR granted precautionary measures for 135 inhabitants of San Juan Copala, Mexico. The request for precautionary measures alleges that 135 members of the Triqui indigenous people of San Juan Copala, in Oaxaca state, are displaced as a result of repeated violent attacks carried out against them by an armed group. The information received indicates that in the previous eleven months, 25 persons have been killed and 17 injured as a result of the acts of violence in San Juan Copala. The Inter-American Commission requested that the State of Mexico adopt the necessary measures to guarantee the life and personal integrity of the 135 inhabitants of San Juan Copala, Mexico; reach agreement with the beneficiaries and their representatives on the measures to be adopted; and inform the Commission about the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 157-09 − Yesid Ramírez Bastidas, Colombia

On September 13, 2010, the IACHR granted precautionary measures for Yesid Ramírez Bastidas, in Colombia. The request for precautionary measures alleges that Yesid Ramírez Bastidas has been subject to illegal telephone interceptions and intelligence activities on the part of agents of the Administrative Department of Security (DAS). The request and additional information provided by the applicants further indicate that neither Yesid Ramírez Bastidas nor his family were guaranteed a security plan following his term as a magistrate, which ends on September 30, 2010. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and personal integrity of Yesid Ramírez Bastidas, reach agreement with the beneficiary on the measures to be adopted, and inform the Commission on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 243-10 − Sigifredo Espinosa Pérez and his Family, Colombia

On September 13, 2010, the IACHR granted precautionary measures for Sigifredo Espinosa Pérez and his family, in Colombia. The request for precautionary measures alleges that Sigifredo Espinosa Pérez has been subject to being followed, purportedly as a result of his participation in investigations into alleged ties between public officials and armed groups operating outside the law. The information received further indicates that Espinosa Pérez had allegedly been subject to illegal telephone interceptions and intelligence activities on the part of agents of the Administrative Department of Security (DAS). The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and personal integrity of Sigifredo Espinosa Pérez and his family, reach agreement with the beneficiary on the measures to be adopted, and inform the Commission on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 254-10 − Leiderman Ortiz Berrio, Colombia

On August 20, 2010, the IACHR granted precautionary measures for Leiderman Ortiz Berrio, in Colombia. The request for precautionary measures indicated that the journalist Leiderman Ortiz Berrio has been the victim of a series of attacks in recent months, purportedly because of his reporting on illegal gangs. It added that the last attempt on his life took place on May 20, 2010, with the explosion of a grenade in his house in the municipality of Caucacia, in Colombia's department of Antioquia. According to the information received, to date the authorities have not provided protection arrangements for Ortiz Berrio. The Inter-American Commission requested that the State of Colombia adopt the necessary measures to guarantee the life and personal integrity of Leiderman Ortiz Berrio, that it reach agreement with the beneficiary and his representatives on the measures to be adopted, and that it inform the Commission about the steps taken to prevent new acts of violence or intimidation against the beneficiary.

PM 185-07 − Norma Cruz Córdova and Alan Maldonado Ordóñez, Guatemala

On August 18, 2010, the IACHR expanded Precautionary Measures 185-07 to incorporate as beneficiaries  Norma Cruz Córdova and Alan Maldonado Ordóñez, members of the Survivors Foundation (Fundación Sobrevivientes) of Guatemala. It is alleged that in June 2010, Norma Cruz Córdova received death threats in connection with a legal case brought by the foundation. The Commission's decision modifies precautionary measures originally granted on October 26, 2007. The Commission asked the State of Guatemala to adopt the measures necessary to guarantee the life and physical integrity of the beneficiaries, reach agreement with the beneficiaries and their representatives on the measures to be adopted, and inform the Commission on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 252-10 − Álvaro Javier Martínez Torres et al., Colombia

On August 13, 2010, the IACHR granted precautionary measures for Álvaro Martínez Torres and others, in Colombia. The request for precautionary measures alleges that the Martínez family was in a situation of imminent risk, purportedly due to his activities to vindicate the rights of his family and other displaced persons on the "La Alemania" farm, in the town of San Onofre, department of Sucre, as well as his actions to clarify the events that led to the death of Rogelio Martínez, who was allegedly murdered on May 18, 2010, by armed groups operating outside the law. The Inter-American Commission requested that the State of Colombia adopt the necessary measures to guarantee the life and personal integrity of Julia Isabel Torres, Luis Miguel Martínez Torres, Mabelis Martínez Torres, Luis Miguel Martínez Torres,  Álvaro Javier Martínez Torres, Kelly Johana Martínez, Luis Fernando Martínez, Isabel Sofía Martínez, and Luz Nellis Martínez; that it reach agreement with the beneficiaries and their representatives on the measures to be adopted; and that it inform the Commission about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 259-10 − Marco Vinicio Hernández González et al.

On August 13, 2010, the IACHR granted precautionary measures for Marco Vinicio Hernández González and the immediate family of Juan Fidel Pacheco Coc, in Guatemala. The request for precautionary measures alleges that Juan Fidel Pacheco Coc, Secretary General of the General Labor Union of Employees of the General Directorate of Migration of Guatemala (USIGEMIGRA), was murdered on July 31, 2010, after receiving threats. That same day, Marco Vinicio Hernández González, Assistant Secretary General of USIGEMIGRA, allegedly received threats in which he was told that he was "next on the list." It is alleged that in May 2010, Mr. Pacheco Coc asked the appropriate authorities for protection measures for the members of the labor union, but that he had received no response. The Inter-American Commission requested that the State of Guatemala adopt the necessary measures to guarantee the life and  physical integrity of Marco Vinicio Hernández González and the immediate family of Juan Fidel Pacheco Coc; that it reach agreement with the beneficiaries and their representatives on the measures to be adopted; and that it inform the Commission about the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 97-10 − 179 Families of the Settlements of El Vergel and El Pedregal, Department of Cauca, Colombia

On August 13, 2010, the IACHR granted precautionary measures for 179 families living in the settlements of El Vergel and El Pedregal, in the department of Cauca, Colombia. The request for precautionary measures alleges that these families are in a situation of extreme danger as a result of the armed conflict and the lack of measures to protect civilians who live in the area. According to the information provided, the inhabitants of these settlements were victims of bullet wounds, forced displacements, and other alleged acts of violence. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and personal integrity of the 179 beneficiary families; to adopt the necessary measures to guarantee the return, in conditions of security, of the families displaced from El Vergel and El Pedregal; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 102-10 − Inhabitants of the Mixteca Indigenous Community of Lázaro Cárdenas, Putla, Oaxaca, Mexico

On August 4, 2010, the IACHR granted precautionary measures for the inhabitants of the Mixteca indigenous community of Lázaro Cárdenas, Putla, Oaxaca, Mexico. The request for precautionary measures alleges that a series of acts of violence have taken place against the inhabitants of the Mixteca indigenous community of Lázaro Cárdenas, in the state of Oaxaca, in the context of a violent dispute between two communities to define their territory and the access to it. According to the information received, the situation was aggravated in March and May of 2010, with the reported disappearance of Marcelino Pedro Hernández Jiménez and Eleazar Asunción Sánchez Hernández and the purported invasion by approximately 1,500 people from another community, which took place in July 2010 and which allegedly places all inhabitants of Lázaro Cárdenas at risk. The Inter-American Commission asked that the State of Mexico adopt the necessary measures to guarantee the life and personal integrity of the members of the Mixteca community of Lázaro Cárdenas; that it adopt the necessary measures to remove the risk factors tied to the demarcation of lands between both communities, in order to prevent further confrontations; that it establish a mechanism for constant monitoring and ongoing communication with the beneficiaries, so that the measures can be implemented by mutual agreement with the beneficiaries and their representatives; and that it provide updated information on the steps taken to discover the whereabouts of Marcelino Pedro Hernández Jiménez and Eleazar Asunción Sánchez Hernández.

PM 221-10 − Edwin Róbelo Espinal, Honduras

On July 22, 2010, the IACHR granted precautionary measures for Edwin Róbelo Espinal, in Honduras. The request for precautionary measures alleges that Edwin Róbelo Espinal has been subject to threats and harassment, purportedly on the part of police agents, since October 2009, and that this allegedly has to do with his participation in demonstrations. The request adds that on June 30, 2010, Edwin Róbelo Espinal was detained and physically abused by agents of the police. It also indicates that he had not received a response to a request for protection submitted to the relevant authorities. The Inter-American Commission requested that the State adopt the necessary measures to guarantee the life and personal integrity of the beneficiary; come to an agreement with the beneficiary and his representatives on the measures to be adopted; and inform the Commission on the steps taken to investigate the facts that led to the adoption of these measures.

PM 214-10 − Reina Luisa Tamayo Danger, Cuba 

On July 20, 2010, the IACHR granted precautionary measures for  Reina Luisa Tamayo Danger, in Cuba. The request for precautionary measures alleges that Reina Luisa Tamayo Danger  has suffered constant threats and acts of harassment, in light of her involvement in various public protests since the death of her son Orlando Zapata Tamayo in February 2010. The request further indicates that she has been the victim of acts of violence, in which she allegedly was beaten and one of her arms was fractured. The Inter-American Commission asked the State of Cuba to adopt the necessary measures to guarantee the life and physical integrity of Reina Luisa Tamayo Danger, reach agreement with the beneficiary on the measures to be adopted, and inform the Commission on the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 187-10 − Persons Deprived of Liberty in the Third Precinct Police Station of Ensenada, Province of Buenos Aires, Argentina 

On July 2, 2010, the IACHR granted precautionary measures for persons deprived of liberty in the Third Precinct Police Station of Ensenada, in the province of Buenos Aires, Argentina. This precautionary measure was granted at the Commission's initiative following a visit to that police station on June 8, 2010. During the visit, the IACHR observed that 20 individuals were being held in a situation of extreme overcrowding in the jail area, which consists of three windowless cells with no ventilation points and a corridor and bathroom. Three persons sleep in each cell, and eleven sleep on the floor in the corridor. Those in custody are shut inside 24 hours a day, with no access to natural light and without doing any type of productive or recreational activity. Although police station jails are meant to be temporary detention centers, at the time the IACHR visited, all those being held in the Third Precinct Police Station of Ensenada had been there for periods ranging from 3 to 18 months, according to the official records of the population in custody. The IACHR also verified the existence of two persons who were ill and were not receiving adequate medical care, and it was informed that those in custody would not receive medical attention unless it was ordered by a judge, in which case they would have to be transferred to an assistance center. The Inter-American Commission asked the State of Argentina that the persons being deprived of their liberty in the Third Precinct Police Station of Ensenada be immediately placed in a location that complies with the requirements for detention in conditions of dignity.

PM 194-10 − Carolina Pineda, José Luis Buquedano, and Delvid Ixcel Sánchez Ávila, Honduras 

On July 2, 2010, the IACHR granted precautionary measures for Carolina Pineda, José Luis Buquedano, and Delvid Ixcel Sánchez Ávila, in Honduras. The request for precautionary measures alleges that the beneficiaries had been subject to acts of harassment and aggression that put their lives and personal integrity at risk. The request alleges that on June 10, 2010, armed and hooded men attempted to kidnap Carolina Pineda, Secretary of the Central Management Council of the College of Middle Education Professors of Honduras (COPEMH). It adds that on June 12, 2010, José Luis Buquedano, Secretary of the Unified Confederation of Workers (CUTH), Secretary General of the Independent Federation of Honduran Workers, and leader of the National Front for Popular Resistance (FNRP), had reportedly been chased by persons in a vehicle who fired gunshots at him. Finally, the request alleges that Delvid Ixcel Sánchez, a member of the National Front for Popular Resistance and collaborator with the Committee for the Defense of Human Rights (CODEH), had been pursued by an armed man on June 10, 2010. Delvid Ixcel Sánchez identified the assailant as one of a group of four armed individuals that had attacked him on February 25, 2010. The Inter-American Commission asked that the necessary measures be adopted to guarantee the life and personal integrity of the beneficiaries, that agreement be reached with the beneficiaries and their representatives on measures to be adopted, and that the Commission be informed about the investigations undertaken with regard to the facts that led to the adoption of these measures, in order to remove the risk factors.

PM 104-09 − 29 Displaced Families from the Municipality of Argelia, Colombia 

On July 1, 2010, the IACHR granted precautionary measures for 29 displaced families from the municipality of Argelia, in the department of Cauca, Colombia. The request for precautionary measures alleges that 29 families from this municipality had been displaced toward Popayán, after having been victims of alleged threats, acts of violence, pursuits, and disappearances. The request also alleges those who committed these acts were armed groups operating outside the law who had acted with the acquiescence of authorities in the area. The Inter-American Commission requested that the State of Colombia adopt the necessary measures to guarantee the life and physical integrity of 96 individuals who belong to these families identified in the request for precautionary measures and to an additional family that is currently displaced in Bogotá. The IACHR also requested that the State adopt the necessary measures to guarantee the definitive return of these families to the municipality of Argelia in conditions of dignity and security; that a mechanism be established for constant monitoring and ongoing communication with the families displaced from Argelia toward Popayán, so that the measures can be implemented by mutual agreement with the beneficiaries and their representatives; that the Commission be informed about the steps taken to discover the whereabouts of Over Herney Muñoz and Jesús Olivier Alvarado Muñoz; and that the State inform the IACHR about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 179-10 − Egberto Ángel Escobedo Morales, Cuba 

On June 28, 2010, the IACHR granted precautionary measures for Egberto Ángel Escobedo Morales, in Cuba. The request for precautionary measures alleges that Escobado Morales is being deprived of his liberty, that he suffers from health problems, and that the prison authorities are not giving him the medical attention that his health condition requires. The Inter-American Commission asked the government of Cuba to instruct the relevant authorities to conduct medical tests to evaluate the beneficiary's health and provide him with adequate treatment; to adopt these measures in consultation with the beneficiary and his family; and to inform the IACHR about the actions taken to implement the precautionary measures.

PM 180-10 − Juan Ramón Flores, Honduras 

On June 21, 2010, the IACHR granted precautionary measures for Juan Ramón Flores, in Honduras. The request for precautionary measures alleges that the beneficiary, who belongs to the Resistance Movement against the coup d'état, had been subject to kidnapping and threatened at gunpoint. The Inter-American Commission asked that the necessary measures be adopted to guarantee the life and personal integrity of Juan Ramón Flores, that agreement be reached with the beneficiaries and their families on the measures to be adopted, and that the IACHR be informed about the actions taken to investigate the facts that led to the adoption of precautionary measures.

PM 189/10– Ronnie Lee Gardner, United States 

On June 17, 2010, the IACHR granted precautionary measures for Ronnie Lee Gardner, who has been deprived of liberty since 1985 awaiting the death penalty. The request for precautionary measures was presented in the context of a communication about the alleged violation of rights enshrined in the American Declaration. The communication alleges that Mr. Gardner's lengthy incarceration on death row constitutes cruel and unusual punishment, as well as issues related to an alleged lack of due process. Through the precautionary measures, the Commission asked the United States to refrain from executing Mr. Gardner until the former has had an opportunity to issue its decision on the petitioner’s claim regarding alleged violations of the American Declaration.

PM 184/10– David Powell, United States  

On June 14, 2010, the IACHR granted precautionary measures for David Powell, who has been deprived of liberty since 1978 awaiting the death penalty. The precautionary measures were issued in the context of a petition alleging the violation of rights enshrined in the American Declaration. This petition, which is being processed by the Commission, alleges irregularities in the criminal proceedings and that Mr. Powell’s lengthy incarceration on death row constitutes cruel and unusual punishment. Through the precautionary measures, the Commission asked the United States to refrain from executing Mr. Powell until the former has had an opportunity to issue its decision on the petitioner’s claim regarding alleged violations of the American Declaration.

PM 131-09 – Blanca Mesina Nevárez, Silvia Vásquez Camacho, and their Families 

On June 4, 2010, the IACHR granted precautionary measures for Blanca Mesina Nevárez, Silvia Vásquez Camacho, and their families, in Mexico. In the request for precautionary measures and in additional information provided to the IACHR, it is alleged that Ms. Mesina Nevárez and Ms. Vásquez Camacho have been subject to acts of intimidation and harassment that place their lives and personal integrity at risk. It is also alleged that this situation stems from their having reported alleged abuses of authority committed by Baja California public law enforcement agents. The additional information provided at the Commission’s request indicates that there apparently have been delays in implementing a security plan for Ms. Mesina Nevárez, Ms. Vásquez Camacho and their families. The Inter-American Commission asked the State of Mexico to adopt the necessary measures to guarantee the life and personal integrity of Blanca Mesina Nevárez, Silvia Vásquez Camacho, and their families; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the IACHR on the steps taken to investigate the events that led to the adoption of precautionary measures.

PM 221-09 − María Stella Jara Gutiérrez and Son, Colombia 

On June 2, 2010, the IACHR granted precautionary measures for María Stella Jara Gutiérrez and her son, in Colombia. In the request for precautionary measures and in additional information sent later, it is alleged that Judge Jara Gutiérrez, who is in charge of the Palace of Justice case, has received threats from alleged armed groups operating outside the law. It is also alleged that the threats have intensified in recent months, as the date for issuing the final judgment in the case draws near. The information also indicates that there has been a delay in the implementation of a security plan designed to safeguard the life and integrity of Judge Jara Gutiérrez and her youngest son. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and personal integrity of María Stella Jara Gutiérrez and her son; to reach agreement with the beneficiary and her representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the events that led to the adoption of precautionary measures.

PM 196-09, Amplification − Journalists from Radio Progreso, Honduras 

On June 2, 2010, the IACHR expanded Precautionary Measure PM 196-09 for Karla Patricia Rivas Sánchez, José Pablo Peraza Chávez, Rita Suyapa Santamaría Velásquez, Alfredo Bográn, Iolany Mariela Pérez Parada, Rommel Alexander Gómez, Lesly Castro, José Domingo Miranda, Héctor Hernández, Víctor Emilio Borjas, Leticia Castellanos, and Pablo Ordónez, in Honduras. The request for precautionary measures alleges that these journalists, who work at Radio Progreso, have been tailed by vehicles, and that unknown individuals have been keeping the entrance of the radio station under surveillance. The Inter-American Commission asked the State to adopt the necessary precautionary measures to guarantee the life and personal integrity of the journalists who are beneficiaries of this measure; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; to inform the Commission about the steps taken to investigate the events that led to the adoption of these measures; and to inform the IACHR on the implementation of the precautionary measures granted.

PM 260-07 – Communities of the Maya People (Sipakepense and Mam) of the Sipacapa and San Miguel Ixtahuacán Municipalities in the Department of San Marcos, Guatemala

On May 20, 2010, the IACHR granted precautionary measures for the members of 18 communities of the Maya indigenous people: Tres Cruces, Escupijá, Pueblo Viejo, La Estancia, Poj, Sipacapa, Pie de la Cuesta, Cancil, Chual, Quecá, Quequesiguán, San Isidro, Canoj, Ágel, San José Ixcaniché, San José Nueva Esperanza, San Antonio de los Altos, and Siete Platos, in Guatemala. The request for precautionary measures alleges that in November 2003, the Ministry of Energy and Mines granted the Montana company a license to mine for gold and silver for 25 years, within an area of 20 square kilometers in the municipalities of Sipacapa and San Miguel Ixtahuacán. The concession’s environmental and hydrological impact area would encompass the territories of at least 18 communities of the Maya people in both municipalities. The petitioners allege that the mining concession was issued and mining began without the prior, complete, free, and informed consultation of the affected communities of the Maya people. Montana reportedly began constructing the Marlin I Mine in 2003 and extracting gold and silver in 2005. The petitioners maintain that the mining has produced grave consequences for the life, personal integrity, environment, and property of the affected indigenous people, since the Tzalá River and its tributaries are the only sources of water for consumption and subsistence activities. According to the request, a number of water wells and springs have dried up, and the metals present in the water as a result of the mining activity have had harmful effects on the health of members of the community. The Inter-American Commission asked the State of Guatemala to suspend mining of the Marlin I project and other activities related to the concession granted to the company Goldcorp/Montana Exploradora de Guatemala S.A., and to implement effective measures to prevent environmental contamination, until such time as the Inter-American Commission on Human Rights adopts a decision on the merits of the petition associated with this request for precautionary measures. The IACHR likewise asked the State to adopt the necessary measures to decontaminate, as much as possible, the water sources of the 18 beneficiary communities and to ensure their members access to water fit for human consumption; to address the health problems that are the subject of these precautionary measures, in particular to begin a health assistance and health care program for the beneficiaries aimed at identifying those who may have been affected by the consequences of the contamination, so as to provide them with appropriate medical attention; to adopt any other necessary measures to guarantee the life and physical integrity of the members of the 18 aforementioned Maya communities; and to plan and implement the protection measures with the participation of the beneficiaries and/or their representatives.

On December 7, 2011, after examining additional information submitted by the State and the petitioners, the IACHR notified its decision to modify these precautionary measures, and requested the State of Guatemala to adopt the necessary measures to ensure that all beneficiary members of the 18 Mayan communities have access to potable water appropriate for human consumption and household use, as well as for irrigation purposes. Specifically, the IACHR requested the State to take the necessary measures, in order that the 18 beneficiary communities’ water resources are not contaminated by mining activities.

PM 141-10 − X and Her Two Children, Colombia 

On May 11, 2010, the IACHR granted precautionary measures for Ms. X, whose identity the IACHR is withholding, and for her two children, who are minors, in Colombia. The request for precautionary measures alleges that Ms. X has been subject to threats and acts of harassment since she reported having been raped by agents of the State in July 2009. The request indicates that following new threats she received in May 2010, Mrs. X moved to another city. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and physical integrity of X and her two children; to reach agreement with the beneficiary and her representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the events that led to the adoption of precautionary measures.

PM 196-09, Amplification – Inmer Genaro Chávez and Lucy Mendoza, Honduras

On May 3, 2010, the IACHR expanded Precautionary Measure PM 196-09 for Inmer Genaro Chávez and Lucy Mendoza, in Honduras. The request for precautionary measures alleges that journalist Inmer Genaro Chávez, who works at Radio Progreso, has received death threats, including a text message sent to his cell phone that said, “Resistance we are eliminating the chebes next come the priests,” after journalist Luiz Chévez and his cousin Alberto Chévez were killed on April 11, 2010. The request also alleges that the lawyer and human rights defender Lucy Mendoza, who has been supporting Radio Progreso journalists in criminal proceedings, has also received death threats. The Inter-American Commission asked that the State adopt the necessary measures to guarantee the life and personal integrity of Inmer Genaro Chávez and Lucy Mendoza, that agreement be reached with the beneficiaries and their representatives on the measures to be adopted, and that the Commission be informed on the steps taken to investigate the facts that led to the adoption of these measures.

PM 114-10 − Persons Deprived of Liberty in the Judicial Police Department (DPJ) of Vila Velha, Brazil 

On April 28, 2010, the IACHR granted precautionary measures for those persons deprived of liberty in the Judicial Police Department (DPJ) of the city of Vila Velha, in the state of Espíritu Santo, Brazil. The request for precautionary measures indicates that the life, personal integrity, and health of those deprived of liberty in the Vila Velha DPJ are at risk. It adds that an average of 160 people, both accused and convicted persons, are being held, in inhuman and degrading conditions, in a cell with the capacity to hold 36 persons. The Inter-American Commission asked the State of Brazil to adopt the necessary measures to protect the life, personal integrity, and health of those persons deprived of liberty in the Judicial Police Department of the city of Vila Velha, in the state of Espíritu Santo, and to provide adequate medical attention to the beneficiaries and prevent the transmission of contagious diseases. The Commission also asked that the measures be adopted in consultation with the beneficiaries' representatives, that the Commission be informed as to the measures adopted to reduce overpopulation in the facility, and that it be informed regarding the failure to divide inmates who are accused from those who have been convicted.

PM 250-09 − José Alejandro Solalinde Guerra and Members of the Hermanos en el Camino Migrant Shelter, Mexico 

On April 23, 2010, the IACHR granted precautionary measures for José Alejandro Solalinde Guerra, David Álvarez Vargas, Areli Palomo Contreras, Mario Calderón López, and Norma Araceli Doblado Abrego, who work or can be found at the Hermanos en el Camino Migrant Shelter in Ixtepec, in the state of Oaxaca, Mexico. In the request for precautionary measures and in information provided during a working meeting held on March 20, 2010, during the Commission's 138th period of sessions, it is alleged that the beneficiaries had been subject to acts of intimidation and that in February 2010, Father Solalinde Guerra was detained and held at gunpoint by the Federal Police when he went to the Office of the Public Prosecutor of Oaxaca state in the context of investigations underway for the alleged murder of three migrants. The petitioners indicate that the protection measures implemented by the authorities turned out to be ineffective, and they inform the Commission that the acts of harassment continue. The Inter-American Commission asked that the State of Mexico adopt the necessary measures to guarantee the life and personal integrity of José Alejandro Solalinde Guerra, David Álvarez Vargas, Areli Palomo Contreras, Mario Calderón López, and Norma Araceli Doblado Abrego; that the planning and implementation of the protection measures be done in agreement with the beneficiaries and their representatives; and that the Commission be informed about the measures adopted to remove the risk factors for the beneficiaries.

PM 312-09 - Father Pedro Pantoja Arreola and his Team of Collaborators at the Belén Migrant Shelter, Mexico 

On April 23, 2010, the IACHR granted precautionary measures for Father Pedro Pantoja Arreola and his team of collaborators at the Belén Migrant Shelter in Saltillo, in the state of Coahuila, Mexico. In the request for precautionary measures and in information provided during a working meeting held on March 20, 2010, during the Commission's 138th period of sessions, it is alleged that the beneficiaries had been subject to acts of intimidation and harassment, an unsuccessful break-in attempt at the shelter's facilities, and surveillance by individuals in vehicles who take photographs of those who enter and leave the shelter. The Inter-American Commission asked that the State of Mexico adopt the necessary measures to guarantee the life and personal integrity of Father Pedro Pantoja Arreola and his team of collaborators at the Belén Migrant Shelter in Saltillo, in the state of Coahuila, Mexico. The IACHR also asked that the planning and implementation of the protection measures be done in agreement with the beneficiaries and their representatives, and that the Commission be informed about the measures adopted to remove the risk factors for the beneficiaries.

PM 196-09, Amplification - Rebeca Ethel Becerra Lanza and Daughters, Honduras 

On April 13, 2010, the IACHR expanded Precautionary Measure PM 196-09 for Rebeca Ethel Becerra Lanza and daughters, in Honduras. The request for precautionary measures alleges that Ms. Becerra had been subject to surveillance in front of her house, times in which she was followed, an attempted break-in at her house, and intimidating phone calls. The request indicates that the acts were reported to the Public Ministry, but that the authorities had not acted. The Inter-American Commission requested that the necessary measures be adopted to guarantee the life and personal integrity of Rebeca Ethel Becerra Lanza and her daughters, that the measures to be adopted be agreed on by the beneficiaries and their representatives, and that the Commission be informed about the steps taken to investigate the facts that led to the adoption of these measures.

PM 304-08 - Diomedes Meneses Carvajalino, Colombia 

On April 9, 2010, the IACHR granted precautionary measures for Diomedes Meneses Carvajalino, in Colombia. The request for precautionary measures alleges that the life and health of Mr. Meneses Carvajalino are in grave danger, as the prison he is in has not provided him with adequate medical care to address a health problem he has had since the beginning of 2009. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to provide adequate medical care that makes it possible to protect the life, personal integrity, and health of Mr. Meneses Carvajalino; to reach agreement with the beneficiary and/or his representative on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the precautionary measures.

PM 222-09 - Agustín Humberto Estrada Negrete, Leticia Estrada Negrete, and Guadalupe Negrete Silva, Mexico 

On April 7, 2010, the IACHR granted precautionary measures for Agustín Humberto Estrada Negrete, Leticia Estrada Negrete, and Guadalupe Negrete Silva, in Mexico. The request for precautionary measures alleges that Mr. Estrada Negrete, a member of the nongovernmental organization Agenda Lesbianas Gays Bisexuales Transexuales [Lesbian, Gay, Bisexual, and Transsexual Agenda] had been subject to death threats, acts of physical violence, and harassment since February 2009. It adds that these acts had been reported to the appropriate authorities, but that the necessary protection measures had not been adopted. It indicates that Mr. Estrada Negrete, his mother, and his sister had received new threats in January and February of 2010. The Inter-American Commission asked the State of Mexico to adopt the necessary measures to guarantee the life and physical integrity of Agustín Humberto Estrada Negrete, Leticia Estrada Negrete, and Guadalupe Negrete Silva; to plan and implement the protection measures with the participation of the beneficiaries and/or their representatives; and to inform the Commission about the measures adopted to respond to the factors that place the beneficiaries at risk.

PM 36-10 - Rodrigo Callejas Bedoya and Family, Colombia 

On April 12, 2010, the IACHR granted precautionary measures for Rodrigo Callejas Bedoya and his family, in Colombia. The request for precautionary measures alleges that Rodrigo Callejas Bedoya has subject to threats and harassment, allegedly because of his work as an independent journalist; as a result, his life and personal integrity, as well as that of his family, are at risk. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and physical integrity of journalist Rodrigo Callejas Bedoya and his family; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of precautionary measures..

PM 99-10 - Tránsito Jurado, María Eugenia González, and Members of the Corporación Sisma Mujer, Colombia 

On April 8, 2010, the IACHR granted precautionary measures for Tránsito Jurado, María Eugenia González, her minor children, and the members of the Corporación Sisma Mujer, in Colombia. The request for precautionary measures alleges that Sisma Mujer and two women who participate in a program coordinated by that organization have been subject to threats, harassment, and one act of violence, allegedly as a result of their work defending the rights of women in a situation of displacement. The request indicates that Ms. González began to receive intimidating telephone calls and to be the target of acts of harassment, starting in September 2009; that on December 4, 2009, an unknown individual approached her on the street and told her to leave Cali with her family; and that eight days later, her son, Jonathan Gómez, was murdered. The request adds that Ms. Jurado has also received death threats, and that on January 27, 2010, Sisma Mujer received an e-mail signed by the "Bloque Metropolitano de las Águilas Negras" [Metropolitan Bloc of the Black Eagles], in which the organization was declared a "military target." The request indicates that Sisma Mujer reported the aforementioned acts and met with the competent authorities, but alleges that the necessary protection measures have not been implemented to date. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and personal integrity of María Eugenia González, her minor children, Tránsito Jurado, and the members of the Corporación Sisma Mujer; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 1-10 - Fourteen Women in a Situation of Displacement, Colombia 

On March 25, 2010, the IACHR granted precautionary measures for 14 women in a situation of displacement in Colombia, whose identity the IACHR is withholding because some of them have suffered sexual violence. The request for precautionary measures alleges that the 14 women are leaders of the displaced community in Bogotá and that as a result of these activities, they have been victims of sexual violence, physical attacks, threats, acts of harassment, and a violent home raid. The request indicates that the beneficiaries met with the Director of the Presidential Human Rights Program on December 22, 2009, and it was agreed that security measures would be taken, but that the agreement had not been implemented to date. It adds that in the time that has passed since that meeting, one of the beneficiaries has suffered an act of sexual violence, and there have been two acts of aggression and one death threat. The Inter-American Commission asked the State of Colombia to adopt the necessary measures to guarantee the life and physical integrity of the 14 women; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of precautionary measures. 

On May 6, 2010, the IACHR expanded the PM 1-10 precautionary measures for Ana María Perea Incel. According to the information sent by the petitioners, Ms. Perea Incel is a member of the Association of Afro Women for Peace and a participant in talks with the government of Colombia on the issue of the rights of the displaced population. It is alleged that on two occasions since December 2009, Ms. Perea Incel was approached in cars by unknown individuals who threatened her with violent acts if she does not leave her work with the Association.

PM 71-10 Claudia Samayoa, Erenia Vanegas, and Members of UDEFEGUA, Guatemala 

On March 25, 2010, the IACHR granted precautionary measures for Claudia Samayoa Pineda, Erenia Yamileth Vanegas Zapata, and their families, as well as the other members of the Unit for the Protection of Human Rights Defenders (UDEFEGUA), in Guatemala. The request for precautionary measures alleges that the beneficiaries have been targets of harassment in recent months as a result of their work and their complaints about alleged abuses of authority committed by State officials. The request alleges that despite the fact that the acts had been reported to the competent authorities, effective protection measures had not been implemented. The Inter-American Commission asked the State of Guatemala to adopt the necessary measures to guarantee the life and physical integrity of Ms. Samayoa and Ms. Vanegas, their families, and the other members of UDEFEGUA; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 79-10 - Nineth Montenegro and Family, Guatemala

 On March 25, 2010, the IACHR granted precautionary measures for Nineth Montegro and her family, in Guatemala. The request for precautionary measures alleges that in early March 2010, Congresswoman Nineth Montenegro Cottom learned of a plan to try to kill her. The request indicates that on March 4, 2010, Ms. Montenegro Cottom met with personnel from the International Commission against Impunity in Guatemala (CICIG), who offered her security measures provided by the Secretariat for Administrative and Security Affairs (SAAS). The request adds that on March 10, Ms. Montenegro Cottom met with personnel from the Ministry of the Interior to discuss the security plan being offered, and expressed her lack of confidence in the services that the SAAS and the National Civilian Police could offer. It also indicates that Ms. Montenegro Cottom would have an armored vehicle, but she believes that she needs a more extensive security scheme. The Inter-American Commission asked the State of Guatemala to adopt the necessary measures to guarantee the life and physical integrity of Congresswoman Nineth Montenegro Cottom and her family, including Alejandra García Montenegro, Emilia García, Mario Alcidez Polanco Pérez, and Carlos Humberto Peraza Ramírez, as well as X, whose identity is being withheld as he is a minor. The Commission also requested that the State reach agreement with the beneficiaries and their representatives on the measures to be adopted and inform the Commission on the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 95-10 - X and Family, Honduras 

On March 24, 2010, the IACHR granted precautionary measures for X, whose identity the IACHR is withholding because he is a minor, as well as for his family, in Honduras. The request for precautionary measures alleges that X, an active member of various student groups and of the National Front for Popular Resistance, has been subject to a kidnapping and to death threats. The Inter-American Commission asked the State of Honduras to adopt the necessary measures to guarantee the life and physical integrity of X and his family; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of precautionary measures.

PM 91-10 - Pedro Brizuela, Mateo Enrique García Castillo, and their immediate families, Honduras 

On March 19, 2010, the IACHR granted precautionary measures for Pedro Brizuela, Mateo Enrique García Castillo, and their respective immediate families, in Honduras. The request for precautionary measures alleges that Pedro Brizuela and Mateo Enrique García Castillo, who belong to the National Front for Popular Resistance, have been targets of acts of violence and harassment. On February 24, 2010, Claudia Brizuela, daughter of Pedro Brizuela, was shot to death by unknown persons when she opened the door to her house. The request for precautionary measures indicates that both before and after his daughter's murder, Mr. Brizuela received threats on his cell phone. It also indicates that on February 26, 2010, Mr. Mateo Enrique García Castillo was the object of a kidnapping attempt by four men who the day before had infiltrated a march convened by the National Front for Popular Resistance. The Inter-American Commission asked the State to adopt the necessary measures to guarantee the life and personal integrity of Pedro Brizuela, Mateo Enrique García Castillo, and their immediate families; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the precautionary measures, in order to remove the factors placing the beneficiaries at risk.

PM 14-10 - X and XX, Mexico 

On March 3, 2010, the IACHR granted precautionary measures for two persons in Mexico whose identity the Commission will withhold because one of the them alleges having been the object of sexual abuse. The request for precautionary measures indicates that the beneficiaries have been subject to threats and harassment since the release of X, who had reportedly been kidnapped on July 6, 2009, in the city of Acapulco, in the state of Guerrero. During the 10 days she was held, she was allegedly drugged, raped, tortured, and kept in chains. The request for precautionary measures alleges that agents of the Ministerial Police were involved in the kidnapping, a connection made because XX had previously reported alleged unlawful actions on the part of State officials. At the time of her release, the kidnappers allegedly threatened to kill her if she reported what had happened. The request indicates that X and her mother, XX, filed a complaint with the Public Ministry and with the Attorney General's Office of the state of Guerrero, where they also requested personal protection measures, but they apparently received no response. The Inter-American Commission asked the State to adopt the necessary measures to guarantee the life and personal integrity of X and XX; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the precautionary measures, in order to remove the factors placing the beneficiaries at risk.

PM 52-10 - Margarita Guadalupe Martínez Martínez and her immediate family, Mexico 

On March 3, 2010, the IACHR granted precautionary measures for Margarita Guadalupe Martínez Martínez, her husband, Adolfo Guzmán Ordaz, and her two children, in San Cristóbal de las Casas, in the state of Chiapas, Mexico. The request for precautionary measures alleges that the beneficiaries are targets of threats and harassment. It indicates that on November 8, 2009, some 18 to 20 individuals, allegedly from the Ministerial Police, came to the beneficiaries' home without a search warrant, threatened Mrs. Martínez Martínez with a firearm, and searched the entire house, including the bedroom in which the children were sleeping. The request adds that this was reported to the authorities and that the beneficiaries asked the authorities for protection, but this was not granted. It also indicates that on February 25, 2010, Mrs. Martínez Martínez was kidnapped and tortured and that her life was threatened by unknown persons, who warned her to desist in her criminal complaint regarding abuse of authority, breaking and entering, psychological torture, and threats, a complaint lodged as a result of the events of November 8, 2009. The request alleges that the kidnappers told her that the attack was "a little gift from the municipal president of Comitán." The Inter-American Commission asked the State to adopt the necessary measures to guarantee the life and personal integrity of Margarita Guadalupe Martínez Martínez, her husband, Adolfo Guzmán Ordaz, and her children, Ada Saraí Martínez Martínez and Eduardo Abel de León Martínez; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the precautionary measures, in order to remove the factors placing the beneficiaries at risk.

PM 43-10 – “Amelia”, Nicaragua

On February 26, 2010, the IACHR granted precautionary measures for a person who the IACHR will identify as Amelia, in Nicaragua. The request seeking precautionary measures alleges that Amelia, mother of a 10-year-old girl, is not receiving the necessary medical attention to treat the cancer she had, because of her pregnancy. The request alleges that the doctors had recommended to urgently initiate chemotherapy or radiotherapy treatment, but the hospital informed Amelia’s mother and representatives that the treatment would not be given, due to the high risk that it could provoke an abortion. The Inter-American Commission asked the State of Nicaragua to adopt the measures necessary to ensure that the beneficiary has access to the medical treatment she needs to treat her metastasic cancer; to adopt the measures in agreement with the beneficiary and her representatives; and to keep her identity and that of her family under seal. Within the deadline set to receive an answer, the State of Nicaragua informed the IACHR that the requested treatment has been initiated
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PM 12-09 – Community of Alto Guayabal–Coredcito of the Emberá People, Colombia


On February 25, 2010, the IACHR granted precautionary measures for 87 families of the Emberá People’s Community of Alto Guayabal-Coredocito—declared “So Bia Drua,” a humanitarian area of the Uradá Jiguamiandó Indigenous Reserve—in the municipality of Carmen del Darién, department of Chocó, Colombia. The request for precautionary measure alleges that this community has been subject to acts of violence that placed their lives and personal integrity at risk. It is alleged, among other facts, that on January 30, 2010, two helicopters and a plane belonging to the armed forces carried out a machine-gun attack and bombing 300 meters from the community’s main settlement, hitting the house of a family where there were three adults and two children, who were wounded. The request indicates, for example, that Mr. José Nerito Rubiano Bariquí was wounded in the thorax with a firearm, as a result of which he broke his spinal column and was left paraplegic. According to the applicants seeking the measures, the military presence in the area is related to the resumption of mining activity. The Inter-American Commission requested that the State of Colombia adopt the measures necessary to protect the life and personal integrity of 87 families of the Community of Alto Guayabal-Coredocito; that it come to an agreement with the beneficiaries and their representatives on the measures to be adopted; and that it inform the Commission on actions taken to investigate the events that led to the adoption of precautionary measures so as to remove the risk factors for the beneficiaries.
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PM 38-10 - Manuel de Jesús Varela Murillo et al., Honduras 

On February 25, 2010, the IACHR granted precautionary measures for Manuel de Jesús Varela Murillo, Ricardo Antonio Rodríguez, and their families, in Honduras. The request for precautionary measures alleges that the beneficiaries, who belong to the Resistance Movement against the coup d'état, had been subject to kidnapping, acts of torture, and death threats. It indicates that on February 2, 2010, they were attacked by 20 individuals in civilian clothing, who were heavily armed and wore ski masks over their faces. It alleges that the beneficiaries were taken to a house where they were blindfolded, hit about the head, and threatened with machetes while being asked where the arsenal was and where the dollars were and being told to abandon the resistance. The beneficiaries indicated that the attackers robbed them of money, a computer, personal documents, and one cell phone. They state that after more than three hours of interrogation and threats to kill their families, they were abandoned in the Víctor Ardon neighborhood. The Inter-American Commission asked the state to adopt the necessary measures to guarantee the life and personal integrity of Manuel de Jesús Varela Murillo, Ricardo Antonio Rodríguez, and their families; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the precautionary measures, in order to remove the factors placing the beneficiaries at risk.

PM 196/09, Amplification - Anselmo Romero Ulloa and María Brígida Ulloa Hernández, Honduras 

On February 12, 2010, the IACHR expanded Precautionary Measure PM 196-09 for Anselmo Romero Ulloa and María Brígida Ulloa Hernández, in Honduras. The request for precautionary measures alleges that Mr. Anselmo Romero Ulloa, a member of the National Coordinating Committee for the Resistance, was attacked on November 3, 2009, by a man armed with an Uzi. It alleges that the attacker fired a volley of gunshots near Mr. Romero's face, which left him deaf in one ear, and that another volley passed very close to María Brígida Ulloa Hernández, who lives with Mr. Romero Ulloa. It adds that a complaint was filed with the National Office of Criminal Investigation in Comayagua, but that the Public Prosecutor's Office has yet to proceed with the case. It also indicates that on January 29, 2010, the same person who attacked Mr. Romero Ulloa in 2009 was prowling around the outside of his house, and that the house has been under surveillance at various times by unidentified individuals. The Inter-American Commission asked the State to adopt the necessary measures to guarantee the life and personal integrity of Anselmo Romero Ulloa and María Brígida Ulloa Hernández; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the these measures. The IACHR asked the State to provide information within a 20-day period and to provide updates on a regular basis..

PM 18-10 − Indyra Mendoza Aguilar et al., Honduras

On January 29, 2010, the IACHR granted precautionary measures for Indyra Mendoza Aguilar, Nohelia Flores Álvarez, Fátima Maritza Ulloa Becerra, and Ana Lourdes Ordóñez, in Honduras. Indyra Mendoza Aguilar is the director of Cattrachas, a nongovernmental organization that works for the rights of the lesbian, gay, bisexual, transgender, and intersex (LBGTI) community. The request for precautionary measures alleges that on December 17, 2008, in Tegucigalpa, Nohelia Flores Álvarez, who belongs to Cattrachas, was forced to get into a vehicle of a member of the Preventive Police, who demanded sexual services at gunpoint. The request indicates that Nohelia Flores Álvarez refused, and the police officer threatened his life. It goes on to say that the next day, the policeman returned with two other men in a pickup truck and the three of them stabbed him a total of 17 times, in his throat, back, stomach, and arms. After he passed out, the men abandoned him in some bushes. In the hospital, Indyra Mendoza took photos that could serve as evidence in a trial and accompanied him in the process of filing the complaint, which is being investigated by Fátima Maritza Ulloa Becerra and Ana Lourdes Ordóñez, agents of the National Office of Criminal Investigation in Tegucigalpa. The request for precautionary measures alleges that the four beneficiaries are the object of threats and acts of harassment that place their lives and personal integrity at risk. The Commission requested that the State of Honduras adopt the necessary measures to guarantee the life and personal integrity of Indyra Mendoza Aguilar, Nohelia Flores Álvarez, Fátima Maritza Ulloa Becerra, and Ana Lourdes Ordóñez; that it come to an agreement with the beneficiaries and their representatives on the measures to be adopted; and that it inform the Commission about the actions taken with respect to the events that led to the adoption of the precautionary measures, so as to remove the factors placing the beneficiaries at risk
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PM 385-09 – 31 Undocumented Immigrants Residing in Atlanta, Georgia, United States  

On January 29, 2010, the IACHR granted precautionary measures for 31 undocumented immigrants residing in Atlanta, Georgia, whose dialysis treatments at Grady Memorial Hospital were scheduled to be terminated on February 3, 2010. The request seeking precautionary measures alleges that the lives and health of the 31 persons concerned are at grave risk due to the fact that they suffer from End-Stage Renal Disease and do not have the economic resources to obtain the dialysis treatments that their condition requires. It is alleged that Grady Memorial Hospital’s decision to terminate the dialysis treatments had a disproportionate effect on the beneficiaries because, unlike the affected U.S. citizens, they are not eligible to receive assistance through programs such as Medicare or Medicaid. Furthermore, the petitioners claim that the beneficiaries were not informed of alternative means of obtaining the treatment that they require, but that they were instead encouraged to leave the state of Georgia and return to their countries of origin. The Inter-American Commission asked the United States to instruct the competent authorities to take the urgent measures necessary to ensure that the beneficiaries have access to the medical treatment that may be required for their condition, and to inform the IACHR about compliance with these measures within 10 days, and thereafter on a periodic basis. .

PM 196/09, Amplification - Gilberto Vides and his immediate family, Honduras 

On January 22, 2010, the IACHR expanded Precautionary Measure PM 196-09 for Gilberto Vides and his immediate family. The request for precautionary measures alleges that on January 7, 2010, Professor Gilberto Vides, of the National School of Fine Arts, was approached by two armed men when he was returning from a resistance march. It indicates that they shot at the windshield and back window of his car and then fled. It also alleges that his home was under surveillance on January 8 and 9, 2010. The Inter-American Commission asked the State to adopt the necessary measures to guarantee the life and personal integrity of Gilberto Vides and his wife and daughter; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the these measures.

PM 196-09 - Amplification of Precautionary Measure, Nuclear Family of Rasel Antonio Tome, Honduras

On January 19, 2010, the IACHR amplified Precautionary Measure PM 196/09 for relatives of Rasel Antonio Tome, in Honduras. Rasel Antonio Tome is a beneficiary of IACHR precautionary measures through the amplification granted on September 23, 2009, when he was in the Embassy of Brazil with President Manuel Zelaya. The request for precautionary measures indicates that Rasel Antonio Tome has received death threats, and posters have appeared on the streets of Tegucigalpa bearing his photograph, along with those of other leaders of the Resistance Front, with captions such as "People of Honduras: These are your enemies. Know them." The request also reports that this same message is contained in a TV announcement that runs on Channel 8. It alleges that the security of Rasel Antonio Tome's nuclear family, which consists of his wife and three minor children, is at risk. The Inter-American Commission requested that the State adopt the necessary measures to guarantee the life and personal integrity of the members of Rasel Antonio Tome's nuclear family; that it reach an agreement with the beneficiaries and their representatives on the measures to be adopted; and that it inform the Commission about the actions taken to investigate the events that led to the adoption of these measures. The IACHR asked the State to provide information within a period of 20 days and to provide regular updates
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PM-364/09 Carlos Amilcar Orellana Donis, Guatemala 

On January 19, 2010, the IACHR granted precautionary measures for Carlos Amilcar Orellana Donis, in Guatemala. The request for precautionary measures alleges that in the early morning hours of August 29, 2009, Mr. Carlos Amilcar Orellana Donis was transferred unexpectedly to a maximum-security prison, even though he had not yet been tried. It adds that of the eight persons who have been charged in the case against him, he was the only one who was transferred. It states that the maximum-security prison also houses those who in 2007 allegedly killed the four police officers charged in the same crime in which Mr. Orellana Donis has been accused. The request also alleges that courts in Guatemala have recently issued rulings ordering the return of Mr. Orellana Donis to a preventive detention center, and that the competent Guatemalan authorities have not complied with these rulings. The IACHR asked the State of Guatemala for information in December 2009 but received no response. The Inter-American Commission requested that the State of Guatemala adopt the necessary measures to guarantee the life and physical integrity of the beneficiary and to separate him from the persons deprived of liberty who have already been convicted.

PM 113/07 (Amplification) - Corporación para la Paz y el Desarrollo Social (CORPADES) [Corporation for Peace and Social Development], Colombia


On January 14, 2010, the IACHR extended Precautionary Measure PM 133-07 to protect Guillermo Osorio, Jairo Ivan Maya Rodríguez, Yeisme Romero Fuenmayor, Juan David Muñoz, and Rafael Emiro Bedoya, all of whom belong to the Corporación para la Paz y el Desarrollo Social (CORPADES). The request for precautionary measures alleges that the beneficiaries have received threats from alleged paramilitary groups, due to their community leadership and participation in criminal proceedings brought against members of organizations operating outside the law. The petitioners inform the Commission that on December 20, 2009, John Alexander Pulgarín—a member of CORPADES and a witness in a case brought against the paramilitary member Jhon William López—was killed, despite the fact that the State had apparently provided a protection scheme for him. The IACHR originally granted this precautionary measure on March 14, 2008, for Fernando Quijano, Carlos Mario Arenas, Teresa Muñoz Lopera, Alberto Manzo Monsalve, Dillier Fernando Vásquez Rúa, Santiago Quijano, and Marín Alonso Velásquez, all members of CORPADES. The request for precautionary measures alleges that the members of this organization have been targets of threats and attacks allegedly committed by groups operating outside the law. The Commission asked the Colombian State to adopt the necessary measures to guarantee the life and physical integrity of the beneficiaries, as well as to inform the Commission about the steps taken to clarify judicially the events that led to the adoption of precautionary measures. The Commission will continue to monitor the situation.

PM 380-09 – María Lourdes Afiuni, Venezuela  

On January 11, 2010, the IACHR granted precautionary measures for Maria Lourdes Afiuni, Venezuela. The request seeking precautionary measures alleges that on Sunday, January 3, 2010, a group of persons deprived of liberty in the Instituto Nacional de Orientación Femenina (INOF) wore distinctive tape in their legs and head, which allegedly means “war” or “mutiny”, and planned to “burn the judge alive,” in reference to Mrs. Afiuni. It is alleged that they also planned to hurt other three persons detained who are perceived to be close to Mrs. Afiuni. The Inter-American Commission asked the State of Venezuela to adopt the measures necessary to guarantee the life and physical integrity of the beneficiary; to adopt the measures necessary to transfer the beneficiary to a safe place, and to inform the IACHR about actions taken to investigate through the Judiciary the facts that led to the adoption of precautionary measures.

PM 209-09 – Franklin José Brito Rodríguez, Venezuela

On January 11, 2010, the IACHR granted precautionary measures for Franklin José Brito Rodríguez, Venezuela. The request for precautionary measure alleges that in the early morning hours of December 13, 2009, agents of the Metropolitan Police of Caracas moved Franklin José Brito, who had been carrying out a hunger strike in front of the OAS office in Caracas, to the Military Hospital. Mr. Brito alleges that he is being unlawfully deprived of his personal liberty, as he is being held in the facility against his will. It is alleged that he was transferred to the Military Hospital in response to an amparo action filed by the Public Ministry on the grounds of safeguarding his life. However, the request argues that the amparo is arbitrary, since it does not meet any of the assumptions established in the law for an amparo action. The Commission was also informed that as of January 6, 2010, Mr. Brito was still in the Military Hospital without having access to a medical doctor he trusted. Finally, the Commission was informed that on January 9, 2010, State officials allegedly sedated him against his will and transferred him again, telling his daughter that they were taking him for intensive therapy. The Inter-American Commission asked the State of Venezuela to adopt the measures necessary to permit access, treatment, and monitoring of Mr. Brito’s health situation, and to ensure that Mr. Franklin Brito can receive regular visits. The IACHR also requested that the State inform the Commission within a 10-day period on the adoption of precautionary measures and update that information on a regular basis.

PM 196/09, Amplification - Marbin Emilio Hernández Duarte and his immediate family, Honduras 

On January 8, 2010, the IACHR expanded Precautionary Measure PM 196-09 for Marbin Emilio Hernández Duarte and his immediate family. Mr. Duarte belongs to a group that does outreach activities related to the Resistance Front and to situations of repression following the June 2009 coup d'état. The request for precautionary measures alleges that on October 18, 2009, the group organized the presentation of a video in the Divanna de Comayagüela neighborhood, where unknown individuals took photos of the group and of the coordinators of the Resistance Front. The request notes that the following day Marco Antonio Martínez Lezama, the coordinator of the resistance movement in that neighborhood, was found dead. The request adds that on October 28, 2009, the same video was shown in the neighborhood of La Fraternidad de Tegucigalpa, and that once again unknown individuals took photos of them. It was reported that on December 22, 2009, Edwin Renán Fajardo Argueta, a member of the group, was found dead at his home and that on that date unknown individuals had followed Mr. Duarte. The request adds that on December 29 journalist César Silva, another member of the group, was kidnapped. It adds that on December 31, 2009, two men with military-style haircuts approached Mr. Duarte's residence, where his two children were playing outside, asked the 9-year-old boy for water, and asked the 5-year-old boy what his father's name was. The Inter-American Commission asked the State to adopt the necessary measures to guarantee the life and personal integrity of Marbin Emilio Hernández Duarte and his family; to reach agreement with the beneficiaries and their representatives on the measures to be adopted; and to inform the Commission about the steps taken to investigate the facts that led to the adoption of the these measures. The IACHR asked the State to provide information within a 20-day period and to provide updates on a regular basis.

About Precautionary Measures

The inter-American human rights system has used precautionary measures for over three decades, and has served as a tool for protecting the basic rights of the people of the 35 states that are subject to the Inter-American Commission’s jurisdiction.  The IACHR’s authority to request urgent measures or order precautionary measures is reflective of a common practice in international human rights law.  In the particular case of this region, it has been invoked to prevent and protect against potential serious and irreparable harm to persons or groups of persons who are in imminent peril.   The Commission has thus been performing its assigned mandate under Article 106 of the OAS Charter, which is “to promote the observance and protection of human rights” and has also been helping the States perform their ineluctable and abiding duty, which is to protect human rights.  The precautionary measures mechanism has shown it effectiveness and has been recognized by the beneficiaries, the OAS member states, the users of the inter-American system, and the human rights community as a whole.

The history and legal framework of precautionary measures

Precautionary measures are frequently used in international law. The principal international courts and treaty-based bodies are authorized to order precautionary measures so that their decisions and the protection they are intended to afford are not mere abstractions.  Since its establishment, the Commission has requested protective measures from the States, which are urgent measures the States must take to avoid irreparable harm to the beneficiaries’ life or personal integrity.  In the history of precautionary measures within the inter-American system, the IACHR’s 1980 Regulations (as they were then called in English) established a formal procedure for this mechanism. Article 26 of the then Regulations provided that “provisional measures” were called for “[i]n urgent cases, when it becomes necessary to avoid irreparable damage to persons.”   The formal establishment of this mechanism within the Commission’s Rules of Procedure and its gradual development through application in practice fit the pattern by which the inter-American human rights system has traditionally cultivated its mechanisms of protection.  This article follows from the IACHR’s duty to ensure compliance with the commitments undertaken by the states parties, a duty set forth in Article 18 of the Commission’s Statute and Article 41 of the American Convention, and is based on the states’ general obligation to respect human rights and to ensure their free and full exercise to all persons subject to their jurisdiction (Article 1 of the American Convention), to adopt legislative and other measures necessary to give effect to those rights (Article 2), and to comply in good faith with the obligations undertaken in the Convention and the OAS Charter.  The states themselves have frequently acknowledged how vital precautionary measures have been to ensuring the effective observance of human rights in very serious and urgent circumstances.

Recognizing the intrinsic value of the work that the Inter-American Commission performs, the OAS General Assembly has encouraged the member states to follow up on the Commission’s recommendations and precautionary measures.  When the General Assembly adopted the Inter-American Convention on Forced Disappearance of Persons in 1994, the member states acknowledged how effective precautionary measures were for purposes of examining allegations of this nature.

The system of precautionary measures has been a feature of the Commission’s Rules of Procedure for over 30 years. The most recent amendment of the Rules of Procedure took effect on December 31, 2009.  Article 25 describes the procedure for precautionary measures and how a precautionary measure may be related to the subject matter of a petition or case (Article 25.1); the adoption of precautionary measures independently of any pending petition or case (Article 25.2); the individual or collective nature of precautionary measures (Article 25.3); the fact that the IACHR is to request relevant information from the state concerned, unless the urgency of the situation is such that the immediate granting of the measures is warranted (Article 25.5); the procedures for seeking withdrawal of the request for precautionary measures and the grounds for the Commission to withdraw its request for precautionary measures (articles 25.7 and 25.8), and other points.  In the amendment process, the Commission gave extensive consideration to the comments and criticisms submitted by many OAS member states, civil society organizations, academics and private citizens from across the hemisphere, in response to the consultations instituted concerning the text of the preliminary draft amendment.

Precautionary measures: their use as a means of ensuring observance of fundamental rights and preventing irreparable harm

In the last 30 years, precautionary measures have been invoked to protect thousands of persons or groups of persons at risk by virtue of their work or affiliation.  They include human rights defenders, journalists, trade unionists, vulnerable groups such as women, children, Afro-descendant communities, indigenous peoples, displaced persons, LGTBI communities and persons deprived of their liberty.  They have also been used to protect witnesses, officers of the court, persons about to be deported to a country where they might be subjected to torture or other forms of cruel and inhuman treatment, persons sentenced to the death penalty, and others.  The IACHR has also ordered precautionary measures to protect the right to health and the right of the family.  It has also resorted to precautionary measures in situations involving the environment, where the life or health of persons or the way of life of indigenous peoples in their ancestral territory may be imperiled, and in other situations.

Precautionary measures serve two functions related to the protection of fundamental rights recognized in the provisions of the inter-American system.  They serve a “precautionary” function in the sense that they preserve a legal situation brought to the Commission’s attention by way of cases or petitions; they also serve a “protective” function in the sense of preserving the exercise of human rights.  In practice, the protective function is exercised in order to avoid irreparable harm to the life and personal integrity of the beneficiary as a subject of the international law of human rights.  Precautionary measures have, therefore, been ordered for a wide array of situations unrelated to any case pending with the inter-American human rights system. 

In the case of the precautionary function, the measures ordered may be intended to prevent execution of judicial, administrative or other measures when it is alleged that their execution could render the IACHR’s eventual decision on an individual petition moot. The kinds of situations the IACHR has had occasion to address to preserve the subject of a petition or case have included, inter alia, requests to suspend deportation or extradition orders when there is a risk that the individual being deported or extradited might suffer torture or other cruel and inhuman treatment in the receiving country; situations in which the IACHR has urged a State to suspend application of the death penalty; situations in which the IACHR’s purpose has been to protect an indigenous people’s territory from incursions that might break the close relationship that exists between the indigenous people and its ancestral lands and natural resources, or endanger the survival of its culture.  When it orders precautionary measures in such circumstances, the IACHR is asking the state to suspend any and all activity that could result in a violation of the party on whose behalf it is requesting those measures, until such time as the organs of the inter-American system have had an opportunity to address the merits of the matter in question.

The IACHR has ordered precautionary measures to protect a wide array of rights, such as the rights to health and to family when the conditions of gravity, urgency and a risk of irreparable harm are present.  It has also had occasion to order measures to avoid harm to life or health as a result of environmental contamination. 

When it examines a request seeking precautionary measures, the Commission looks for three essential preconditions: i) gravity; ii) urgency, and iii) the risk of irreparable harm to persons.

The Commission’s examination of requests seeking precautionary measures looks at the specifics of each situation.  Hence, the Commission’s analysis cannot be governed by strict criteria that must apply to each and every case; instead, it has to look at the nature of the risk and the harm that the precautionary measure seeks to avert.  With this clarification, the following are some examples of the factors that the Commission has weighed when considering requests seeking precautionary measures. These factors ought not to be construed as an exhaustive list of the preconditions that must be met for precautionary measures to be granted.

As for the “urgent” nature of the situation for which measures are sought, the risk or threat involved must be imminent, which means that the remediation response must be immediate; hence, when examining this aspect, one has to consider the timing and duration of the precautionary or protective intervention requested.  The following are among the factors that the IACHR considers when assessing this aspect: a) the existence of cyclical threats and assaults, which strongly suggests the need to take immediate action; b) the continuing nature of the threats and how close one follows upon the other, and other factors.

For purposes of assessing the gravity and urgency requirements, the IACHR also considers information describing the events that are triggered the request (telephone threats, written threats, assaults, acts of violence, accusations); the identity of the source of the threats (private parties, private parties with ties to the State, State agents, others); the complaints made to the authorities; the protective measures that the potential beneficiary has already received and information concerning their effectiveness; a description of the context, which is needed to assess the gravity of the threats; the chronology and proximity in time of the threats made; the identity of the persons affected and, where relevant, the group to which they belong and the degree of risk.

The IACHR also considers factors related to the setting in the country concerned, such as: a) the existence of an armed conflict; b) the existence of a state of emergency; c) the efficacy of the judicial system and the severity of the problem of impunity; d) indicia of discrimination against vulnerable groups, and e) the control that the executive branch exercises over the other branches of government, and other factors.

On the matter of irreparable harm, the events that warrant the request must suggest that there is a reasonable probability that the harm will materialize; the request must not rely on legal rights or interests that can be remedied.

It is important to make the point that filing a complaint with local authorities is not a necessary precondition that must be met for precautionary measures to be granted.  However, as Article 25(4) of the Commission’s Rules of Procedure states, it is a factor that the Commission will consider when deciding whether to request precautionary measures from a State.  Correspondingly, when a matter has been brought to the attention of the local authorities, the IACHR can consider the efficacy or inefficacy of the State’s response. Likewise, if the party requesting precautionary measures has not filed a complaint with the local authorities, it is important for the Commission to know the reasons for reframing from doing so.

Before arriving at a final decision as to whether to grant or reject the request seeking precautionary measures, the IACHR may request additional information from the person applying for precautionary measures or from the State concerned, or from both.  Much of what the Commission does is to follow up requests for information from the State and from the petitioners.  The failure of the State or of the party requesting precautionary measures to reply to the Commission’s request for information is a factor that the IACHR will consider when deciding whether or not to grant the requested measure.

If the measure is not granted, this does not prevent the petitioner from filing a new request for protection if he or she believes that there are grounds to grant the request or if new circumstances develop.

In compliance with their international obligations, States must provide effective protection to prevent the risk from materializing.   The parties are in the best position to know what type of tangible or other measures are called for to address the situation and prevent further danger.

The IACHR has various tools at its disposal for follow-up and monitoring of precautionary measures:  exchanges of communications; working meetings or hearings convened during the IACHR’s sessions; follow-up meetings during in loco or working visits by the Commission or the country rapporteurs; press releases, thematic reports or country reports. 

The Commission welcomes the States’ positive response to the precautionary measures.  In carrying out the Commission’s requests for precautionary measures, the States have ordered specific protection measures for beneficiaries (for example, bodyguards, security at office buildings, direct lines of communication with the authorities, protection of ancestral territory, and others), taking into account the opinion of the beneficiary and the beneficiary’s representative; their active participation by supplying information requested by the IACHR or participating in working meetings or hearings held to follow up on precautionary measures; creating inter-institutional working groups to implement the protection measures requested by the inter-American system; and introducing compliance with precautionary measures into their case law and legislation.