Grants and extensions

Resolution No. 33/24
PM 1036-23 - Víctor Miguel Ángel Moreno Campaña, Colombia

On May 20, 2024, the IACHR granted precautionary measures in favor of Víctor Miguel Ángel Moreno, community leader and legal representative of the Community Council of Black Communities of Pueblo Rico. According to the request, Mr. Moreno is at risk due to death threats and intimidation attributed to armed groups operating in the area. When analyzing the request, the Commission took into account the alleged facts in light of the context it has been monitoring in Colombia and assessed the protection measures that have been implemented over time. However, given the nature of the threats, the absence of information on progress in the investigative processes, as well as the need to reinforce the protection measures, it was considered that the risk has not been adequately mitigated.

Pursuant to Article 25 of its Rules of Procedure, the IACHR requested that the State of Colombia:

  1. adopt, with an ethnic differential approach, the necessary measures to protect the rights to life and integrity of the beneficiary;
  2. implement the necessary measures so that the beneficiary can carry out his human rights defense activities without being subjected to threats, harassment or other acts of violence in the exercise of his work;
  3. consult and agree upon the measures to be adopted with the beneficiary and his representatives; and
  4. report on the actions taken to investigate the alleged facts that gave rise to this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 32/24
PM 140-24 - Aldemar Solano Cuellar and his son, Colombia

On May 16, 2024, the IACHR decided to grant precautionary measures in favor of journalist Aldemar Solano Cuellar and his son, Aldemar Felipe Solano Obando. The request argued that Solano Cuellar, director of the digital news program “Conexión”, has received death threats from the illegal armed group “Clan del Golfo”, which include details about his residence and family, and extortion demands. The threats have also been directed at his son, who has received similar intimidating calls. Despite complaints and requests for protection, no concrete measures have been implemented to safeguard their safety. The IACHR noted that the threats persist and that Solano Cuellar, after moving for safety, had to return to Villavicencio. The lack of protection has led him to confine himself to his home, affecting his journalistic work. Consequently, pursuant to Article 25 of its Rules of Procedure, the IACHR decided to grant the precautionary measures and requested that the State of Colombia:

  1. adopt the necessary measures to protect the rights to life and integrity of the beneficiaries;
  2. implement the necessary measures so that Aldemar Solano Cuellar can carry out his activities as a journalist without being subjected to threats, harassment, or other acts of violence in the exercise of his work;
  3. consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
  4. report on the actions taken to investigate the alleged facts that led to this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 31/24
PM 288-24 - Joel Antonio García Hernández, Venezuela

On May 13, 2024, the IACHR granted precautionary measures in favor of Joel Antonio García Hernández, lawyer and human rights defender, who has been suffering threats and aggression related to his work in defense of people considered “political prisoners” in Venezuela. Despite having filed complaints and requests for protection to the internal authorities, no protection measures have been implemented by State bodies to prevent further attacks, and no progress has been made in the investigations. For its part, the State, although informed, has not submitted a response. The Commission, after evaluating the allegations, as well as the context of hostility in the country against legal defenders and the lack of response from the State, understands, prima facie, that the requirements of seriousness, urgency, and irreparable harm are present.

In accordance with Article 25 of the Rules of Procedure, the Commission requests that Venezuela:

  1. adopt the necessary measures to protect the rights to life and personal integrity of Joel Antonio García Hernández, in accordance with the applicable international standards and obligations, including acts of risk attributable to third parties;
  2. implement the necessary measures so that the beneficiary can carry out his work as a defense lawyer without being subjected to acts of intimidation, threats, or other acts of violence in the exercise thereof;
  3. consult and agree upon the measures to be adopted with the beneficiary and his representatives; and
  4. report on the actions taken to investigate the alleged facts that led to the adoption of this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 30/24
PM 442-24 - D.M.P., Cuba

On May 12, 2024, the IACHR granted precautionary measures to D.M.P., political opponent, who has been subjected to beatings, threats and mistreatment, after being deprived of his liberty. It was indicated that he does not receive adequate medical attention for his deteriorating health condition.

The Commission, at the time of evaluating the decision, observed the current conditions of detention of D.M.P., and that the risk factors could be attributed to State agents. For this reason, D.M.P.’s situation of lack of protection is accentuated, not only by the fact that he is classified as a political opponent, but also by the actions taken by the agents responsible for his security to put him at risk. The Commission considered the allegations of collusion between the proposed beneficiary's aggressors and prison officials, in addition to the lack of adequate medical care, to be particularly serious. In addition, the IACHR recognized that the conditions of detention are likely to continue and worsen over time. At the same time, there is no information from the State that would be sufficient to assess whether the alleged situation has been duly mitigated or has disappeared. After analyzing the available information, the IACHR, in accordance with Article 25 of its Rules of Procedure, requested that Cuba

  1. adopt the necessary measures to protect the rights to life, personal integrity, and health of D.M.P.;
  2. ensure that the beneficiary’s detention conditions are compatible with the applicable international standards on the matter;
  3. consult and agree upon the measures to be adopted with the beneficiary and his representatives; and
  4. report on the actions undertaken to investigate the alleged events that led to this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 29/24( EXTENSION )
PM 96-15 - Marienys Pavó Oñate, Cuba

On May 11, 2024, the IACHR extended precautionary measures in favor of Marienys Pavó Oñate regarding Cuba. According to the request, Ms. Pavó Oñate is the wife of Julio Alfredo Ferrer Tamayo, member of the Legal Information Center “Cubalex” and beneficiary of these precautionary measures. The representation alleged that she is being subjected to harassment by State agents since Ferrer Tamayo is outside the country, this is so in retaliation for the work that her husband carries out internationally in the field of human rights and with the objective of preventing him from returning to Cuba. Consequently, under the terms of Article 25 of its Rules of Procedure, the IACHR decided to request that Cuba:

  1. adopt the necessary measures to guarantee the life and personal integrity of Marienys Pavó Oñate;
  2. consult and agree upon the measures to be adopted with the beneficiary and the representation she designates; and
  3. report on the actions implemented to investigate the alleged facts that gave rise to these precautionary measures, so as to prevent such events from reoccurring.

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Resolution No. 28/24
PM 50-24 - Members of the Tapeba Indigenous People of Caucaia, Brazil

On May 9, 2024, the IACHR granted precautionary measures in favor of Members of the Tapeba Indigenous People of Caucaia regarding Brazil. According to the request, the beneficiaries are suffering episodes of violence and threats by organized crime and the police, as well as expulsions from their villages in the context of completion of the demarcation of their lands and protection of their territory. Therefore, in terms of Article 25 of its Rules of Procedure, the IACHR decided to require that Brazil:

  1. adopt the necessary and culturally appropriate measures to protect the life and personal integrity of the members of the Tapeba Indigenous People of Caucaia, including against acts perpetrated by third parties. These measures must allow the leaders of the Tapeba Indigenous People to continue carrying out their work in defense of human rights, as well as guarantee that the beneficiaries can return to their villages without being subjected to threats, persecution, or acts of violence;
  2. coordinate the measures to be implemented with the beneficiaries and their representatives; and
  3. report on the actions taken to investigate the events that led to this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 26/24( EXTENSION AND FOLLOW-UP )
PM 438-15 - Members of the Venezuelan Program of Education-Action on Human Rights (PROVEA) , Venezuela

On April 29, 2024, the IACHR decided to follow up and extend precautionary measures in favor of members of the Venezuelan Program of Education-Action on Human Rights in Venezuela. According to the request, the members of PROVEA are at risk in the context of their work as human rights defenders in the current situation of Venezuela, considering the visibility of the institution and its coordinators, the frequent stigmatizing remarks made by high-ranking State authorities in the media, and the surveillance and monitoring by State agents. Consequently, under the terms of Article 25 of its Rules of Procedure, the IACHR decided to require that Venezuela:

  1. adopt the necessary measures to guarantee the life and personal integrity of the persons identified as members of the PROVEA team;
  2. adopt the necessary measures so that the beneficiaries can carry out their activities as human rights defenders without being subjected to acts of violence, threats, and harassment;
  3. consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
  4. report on the actions taken to investigate the alleged facts that led to these precautionary measures, so as to prevent them from reoccurring.

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Resolution No. 24/24
PM 352-23 - Aniette González García, Cuba

On April 26, 2024, the IACHR granted precautionary measures to Aniette Gonzalez Garcia, who is deprived of her liberty and at risk due to the lack of adequate medical attention for her health problems in the conditions of detention in which she is being held. At the time of assessing the decision, the IACHR noted the conditions of detention and the lack of specialized medical care, which is aggravated by the insufficient food and supplies according to her current health condition. It also observed that she is being subjected to differential treatment by security agents. After analyzing the available information, the IACHR, in accordance with Article 25 of its Rules of Procedure, requested that Cuba

  1. adopt the necessary measures to protect the rights to life, personal integrity and health of Aniette González García, with a gender perspective, in accordance with applicable international standards and obligations;
  2. implement the necessary measures to bring her conditions of detention into line with applicable international standards. In particular, ensuring that the corresponding medical diagnoses are made and that her medical treatment is defined;
  3. consult and agree upon the measures to be adopted with the beneficiary and her representatives; and
  4. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 23/24
PM 384-24 - Walner Omier Blandón Ochoa and ten other persons of the “Puerta de la Montaña” ministry, Nicaragua

On April 21, 2024, the IACHR granted precautionary measures in favor of Walner Omier Blandón Ochoa and ten other persons from the “Puerta de la Montaña” ministry, who are members of the evangelical church “Puerta de la Montaña,” after considering that they are in a serious and urgent situation presenting a risk of irreparable harm to their rights in Nicaragua. The request for precautionary measures alleged that the beneficiaries are deprived of their liberty in “La Modelo” prison and in the Women’s Comprehensive Correctional Facility and despite suffering from a series of health problems, they do not have access to the necessary medical attention or to the required medicines. In the case of Ms. Marisela de Fátima Mejía Ruiz, she is not receiving post-natal health care and adequate food, after having given birth prior to her detention. In addition, the proposed beneficiaries are said to be in inadequate conditions of detention. The Commission also found that the State did not provide any information regarding the measures adopted to mitigate the alleged risk. In accordance with Article 25 of the Rules of Procedure, the Commission requests that Nicaragua:

  1. adopt the necessary measures to protect the rights to life, personal integrity, and health of the beneficiaries. In particular, officially report on their current situation while in State custody;
  2. adopt the necessary measures to ensure that the beneficiaries’ detention conditions are compatible with the applicable international standards on the matter, among them: i. guarantee access to adequate and specialized medical attention, and immediately carry out a specialized medical assessment on their health; ii. ensure access to the necessary treatments and medications to treat their health issues, with the corresponding gender perspective; iii. guarantee regular contact and access to their families and lawyers; and iv. evaluate the possibility of granting alternative measures to the deprivation of liberty given the impossibility of protecting their rights in light of the current detention conditions. iv. evaluate the possibility of granting alternative measures to the deprivation of liberty given the impossibility of protecting her rights in light of the current detention conditions;
  3. consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
  4. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 21/24
PM 280-24 - Julio César Góngora Millo, Cuba

On April 10, 2024, the IACHR granted precautionary measures in favor of Julio César Góngora Millo. It was indicated that Mr. Millo is a human rights activist and has been identified as a “counterrevolutionary” or “dissident” by the State. As a result, he is reportedly suffering threats, intimidation, harassment and surveillance attributed to State agents. In addition to the above, it has been alleged that the beneficiary is being denied medical attention by the State as part of the retaliatory actions against him. After evaluating the available information, the Commission requests that the State of Cuba:

  1. adopt the necessary measures to protect the rights to life and personal integrity of the beneficiary;
  2. adopt the necessary protective measures so that the beneficiary can continue to carry out his work defending human rights, without being subject to threats, intimidation, harassment, and acts of violence. The foregoing implies, among other measures, that the State provide the corresponding medical care so that he can perform his duties; and
  3. report on the actions taken to investigate the alleged events that led to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 19/24
PM 73-24 - Thirteen members of the La Plata Bahía Málaga Community, Colombia

On April 8, 2024, the IACHR decided to grant precautionary measures in favor of thirteen territorial authorities, social leaders and defenders of ethnic-territorial rights of the Community Council of the black communities of La Plata Bahía Málaga, located in Buenaventura, Valle del Cauca. According to the request, the Community Council has resisted claims of territorial control by illegal armed actors and has been suffering armed incursions by these illegal groups since January 2024. The IACHR highlighted the imminence of the risk, underlining the continuity of the threatening events. Consequently, under the terms of Article 25 of its Rules of Procedure, the IACHR decided to grant the precautionary measures and requested that the State of Colombia:

  1. adopt the necessary and culturally appropriate measures to safeguard the life and personal integrity of the beneficiaries. Among other things, it is requested to take the relevant measures to guarantee that they can safely return to their community;
  2. adopt the necessary protection measures so that the beneficiaries can continue carrying out their activities in defense of human rights without being subjected to threats, intimidation, harassment or acts of violence;
  3. consult and agree upon the measures to be adopted with the beneficiaries and/or their representatives; and
  4. report on the actions taken to investigate the alleged facts that gave rise to these precautionary measures, so as to prevent such events from reoccurring.

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Resolution No. 13/24
PM 1109-23 - Selected families of the native Kichwa community Santa Rosillo de Yanayacu, Peru

On March 25, 2024, the IACHR decided to grant precautionary measures in favor of certain families of the native Kichwa community Santa Rosillo de Yanayacu, located in the district of Huimbayoc, Province and Region of San Martin. According to the request, the leader of the community was murdered in November 2023 and the beneficiaries are at risk due to their work in defense of their collective rights. The IACHR highlighted the imminence of the risk, underlining the recent materialization of the murder of the community leader and the continuity of the threatening events. Consequently, under the terms of Article 25 of its Rules of Procedure, the IACHR decided to grant the precautionary measure and requested that the State of Peru:

  1. adopt the necessary and culturally appropriate measures to safeguard the life and personal integrity of the beneficiaries. Among other things, it is requested to adopt the essential measures to ensure that the beneficiaries who are displaced in the city of Tarapoto can return safely to their community;
  2. consult and agree upon the measures to be implemented with the beneficiaries and/or their representatives; and
  3. report on the actions taken to investigate the alleged events that gave rise to these precautionary measures, so as to prevent such events from reoccurring.

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Resolution No. 12/24
PM 51-24 - Cindy Vanessa Arenas Fernández and her family, Colombia

On March 22, 2024, the IACHR granted precautionary measures in favor of Cindy Vanessa Arenas Fernández and her family. Cindy Vanessa, an indigenous woman, was the victim of an attempted feminicide and is reportedly being threatened and persecuted, along with her family, by the identified aggressor and individuals from his circle. Meanwhile, the State indicated that it had determined the application of protection measures, without specifying which ones and the beginning of their implementation. The Commission, after evaluating the various actions of the State, deemed them insufficient to prevent the threatening events from continuing. Furthermore, Cindy Vanessa continued to be subjected to death threats, surveillance, and persecution. The mentioned events also extended to members of her family.

Pursuant to Article 25 of the Rules of Procedure, the Commission requests that Colombia:

  1. adopt the necessary measures to protect the rights to life and personal integrity of Cindy Vanessa Arenas Fernández, Yu'usa Katleen Timaná Arenas, C.L.T.A., and H.S.S.T., with an intersectional approach that considers gender, ethnicity/race, and age, in accordance with the applicable international standards and obligations;
  2. consult and agree upon the measures to be implemented with the beneficiaries and their representatives; and
  3. report on the actions taken in order to investigate the alleged facts that gave rise to the granting of these precautionary measures, so as to prevent such events from reoccurring.

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Resolution No. 11/24
PM 674-21 - J. Santos Rosales Contreras and twelve other members of the Nahua indigenous community of Ayotitlán , Mexico

On March 8, 2024, the IACHR granted precautionary measures in favor of J. de Jesus Santos Rosales and twelve other members of the Nahua indigenous community of Ayotitlán, who are said to actively participate in actions against mining exploitation in their territory. For this reason, the beneficiaries are reportedly facing continuous threats, intimidation, surveillance, monitoring and other acts of violence by organized crime groups, among other actors. For its part, the State indicated that it is in the best disposition to attend the necessary working meetings to reach satisfactory agreements for the indigenous community of Ayotitlán. In addition, the State indicated that it is willing to establish a coordinated work plan between federal and state authorities to address the problem, especially in light of the allegations of the presence of organized crime groups. The State also reported on the incorporation of some of the beneficiaries into the Mechanism for the Protection of Human Rights Defenders and Journalists and the protection measures available to them. Although the Commission valued positively the various actions of the State to address the problem and provide security to the beneficiaries and other members of the Nahua community of Ayotitlán, it also considered that the implementation of the protection measures has not prevented the continuation of threatening events, following the murder of one of the leaders of the community in November 2023. In addition, the beneficiaries have continued to be subject to death threats, threats of disappearance, surveillance at their homes, extortion calls, among others. The aforementioned events have also extended to members of their families.

In accordance with Article 25 of its Rules of Procedure, the Commission requests that Mexico:

  1. adopt the necessary and culturally appropriate measures to guarantee the life and personal integrity of the duly identified beneficiaries;
  2. consult and agree upon the measures to be implemented with the beneficiaries and their representatives; and
  3. report on the actions taken to investigate the alleged events that led to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 10/24
PM 274-24  - Carlos Alberto Bojorge Martínez, Nicaragua

On March 6, 2024, the IACHR granted precautionary measures in favor of Carlos Alberto Bojorge Martínez, after considering that he is in a serious and urgent situation presenting a risk of irreparable harm to his rights in Nicaragua. The request for precautionary measures alleged that Mr. Carlos Alberto Bojorge Martínez, who is a university student and poet, has been missing since January 1, 2024, after being arrested by police officers. It is alleged that on the day of his arrest, he attended a mass at the Metropolitan Cathedral in Managua, wearing a shirt of the Virgin Mary, a small Nicaraguan flag and a picture of Monsignor Arnulfo Romero in reference to the state persecution against the Catholic Church in the country. In the evening hours, he was detained by police officers who took him to an unknown destination, presumably without an arrest warrant and without the reasons for his detention being known. The Commission also found that the State did not provide any information on the measures adopted to mitigate the beneficiary’s risk situation, or on the actions taken to determine the beneficiary’s whereabouts or fate. In accordance with Article 25 of the Rules of Procedure, the Commission requests that Nicaragua:

  1. adopt the necessary measures to determine the situation and whereabouts of Mr. Carlos Alberto Bojorge Martinez, in order to protect his rights to life and personal integrity;
  2. report on the conditions of detention in which he is currently being held. In particular, the Commission also requests that Nicaragua report on the place of his detention, allowing access to his legal representatives and family members, as well as the necessary health care; and
  3. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this resolution, so as to prevent them from reoccurring.

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Resolution No. 7/24
PM 95-24 - Eddy Antonio Castillo Muñoz, Nelly Griselda López García, and Juan Carlos Baquedano, Nicaragua

On March 1, 2024, the IACHR granted precautionary measures in favor of Eddy Antonio Castillo Muñoz, Nelly Griselda López García, and Juan Carlos Baquedano, who are identified or perceived as political opponents of the current Nicaraguan government, after considering that they are in a serious and urgent situation presenting a risk of irreparable harm to their rights in Nicaragua. The request for precautionary measures alleged that the beneficiaries are deprived of their liberty in different prisons and despite suffering from a series of health problems, they do not have access to the necessary medical attention or medicines. In addition, they are reportedly being held in inadequate conditions of detention and are being subjected to aggression by prison officials. The Commission also found that the State did not provide any information regarding the measures adopted to mitigate the risk faced by the beneficiaries. In accordance with Article 25 of the Rules of Procedure, the Commission requests Nicaragua to:

  1. adopt the necessary measures to protect the rights to life, personal integrity, and health of Eddy Antonio Castillo Muñoz, Nelly Griselda López García, and Juan Carlos Baquedano;
  2. adopt the necessary measures to ensure that the beneficiaries’ detention conditions are compatible with the applicable international standards on the matter, including: i. guarantee that they are not subjected to threats, intimidation, harassment, or aggression inside the prison; ii. guarantee access to adequate and specialized medical care, and immediately carry out a specialized medical evaluation of their health; iii. provide the necessary treatments and medications to treat their health issues; iv. guarantee regular contact and access to their family and legal representatives, and v. evaluate the possibility of granting alternative measures to imprisonment given the impossibility of protecting their rights in light of the current detention conditions;
  3. consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
  4. report on the actions taken in order to investigate the alleged events that led to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 6/24
PM 1028-23 - Brenda Evers Andrew, United States

On February 26, 2024, the IACHR granted precautionary measures in favor of Brenda Evers Andrew. The request indicates that Ms. Andrew is at risk given the imminent execution of the death penalty. The applicants also submitted a petition alleging violation of several articles of the American Declaration of the Rights and Duties of Man: due process, right to equality before law, right to a fair trial and adequate defense. In particular, the applicants alleged that her trial was loaded with gender-based stereotypes and a discriminatory narrative. For its part, the State reported that it forwarded the request for precautionary measures to the Attorney General of the state of Oklahoma and reaffirmed its position that the Commission lacks authority to require States to take precautionary measures.

Upon analyzing the submissions of fact and law offered, the Commission considers that the information presented shows prima facie that there is a serious and urgent risk of irreparable harm to Ms. Andrew’s rights to life and personal integrity, in accordance with Article 25 of its Rules of Procedure. Furthermore, should Ms. Andrew be executed before the Commission has the opportunity to examine the merits of his petition, any eventual decision would be irrelevant and would cause irreparable harm. Accordingly, the Commission requests that the United States of America:

  1. adopt the necessary measures to protect the life and personal integrity of Ms. Brenda Evers Andrew; and
  2. refrain from carrying out the death penalty on Ms. Brenda Evers Andrew until the IACHR has had the opportunity to reach a decision on her petition.

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Resolution No. 3/24
PM 999-23 - Juan Carlos Hollman, Argentina

On January 12, 2024, the IACHR decided to grant precautionary measures in favor of Juan Carlos Hollman, who suffers from colon cancer and does not receive timely and adequate medical attention while in detention in Argentina. According to the applicant, Mr. Hollman has not been receiving cancer treatment for more than 23 months and has a prescription for a pending surgery. Although there are judicial decisions determining the provision of the prescribed medical care, he indicated that there are delays in the granting of medical appointments and appointments for examinations, as well as missed appointments due to lack of transportation. Considering the position of special guarantor of the State in relation to the persons under its custody and that the passage of time without receiving prescribed medical treatment may lead to a worsening of their health situation, and eventually, the death of the patient, the IACHR decided to grant precautionary measures under the terms of Article 25 of its Rules of Procedure. Therefore, it requested that Argentina:

  1. adopt the necessary measures to protect the rights to life, personal integrity, and health of Mr. Juan Carlos Hollman. In particular, provide the prescribed medical treatment in a timely and appropriate manner;
  2. consult and agree upon the measures to be adopted with the beneficiary and his representative; and
  3. report on the actions taken in order to investigate the alleged events that led to the adoption of this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 2/24
PM 4-24 - Leyla Susana Lemus Arriaga, Guatemala

On January 13, 2024, the Inter-American Commission on Human Rights (IACHR) decided to grant precautionary measures in favor of the sitting Justice of the Constitutional Court, Leyla Susana Lemus Arriaga, after considering that she is in a serious and urgent situation presenting a risk of irreparable harm to her rights in Guatemala. The request for precautionary measures alleged that on December 11, 2023, the National Civil Police (PNC) patrol car located in front of the beneficiary’s home was set on fire by third parties and that this incident was related to her work as a Justice. The Commission considered that the events of December 11, 2023, occurred when PNC agents were not providing protection to the proposed beneficiary, due to her reassignment by orders of the institution itself and despite the protection detail determined by the State itself. Similarly, the Commission considered that the change in the said security detail was carried out in an uncoordinated manner with the proposed beneficiary and that the State did not designate replacement agents to continue with its proper implementation. Consequently, in accordance with the provisions of Article 25 of its Rules of Procedure, the Commission requested that the State of Guatemala:

  1. adopt the necessary measures to protect the rights to life and personal integrity of Leyla Susana Lemus Arriaga;
  2. adopt the necessary measures to ensure that the beneficiary can carry out her duties as a justice in safe conditions;
  3. consult and agree upon the measures to be adopted with the beneficiary and her representatives; and
  4. report on the actions taken to investigate the alleged facts that led to the adoption of this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 1/24
PM 1088-23 - Irma Elizabeth Palencia Orellana, Guatemala

On January 13, 2024, the IACHR granted precautionary measures in favor of Irma Elizabeth Palencia Orellana after considering that she is in a serious and urgent situation presenting a risk of irreparable harm to her rights in Guatemala. According to the request, Ms. Palencia Orellana, in her capacity as a sitting justice of the Supreme Electoral Tribunal of Guatemala (TSE), is being followed, monitored, threatened, and subjected to other events placing her at risk in the exercise of her position, given the current context of the country. Therefore, based on Article 25 of its Rules of Procedure, the Commission requests that the State of Guatemala:

  1. adopt the necessary measures to guarantee the rights to life and personal integrity of Irma Elizabeth Palencia Orellana;
  2. take the necessary measures to ensure that Irma Elizabeth Palencia Orellana can continue to perform her duties as a sitting justice of the Supreme Electoral Tribunal of Guatemala without being subjected to threats, intimidation, harassment, or acts of violence;
  3. consult and agree upon the measures to be implemented with the beneficiary and her representatives; and
  4. report on the actions taken to investigate the alleged events that led to the adoption of this resolution, so as to prevent such events from reoccurring.

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