IACHR Press Office
Washington, D.C. - The Inter-American Commission on Human Rights (IACHR) condemns the execution of the death penalty imposed on Clarence Wayne Dixon on May 11, 2022, despite the fact that on May 10, 2022, the IACHR granted precautionary measures in his favor, after considering that he was in a serious and urgent risk of irreparable harm to his rights in the United States of America.
The available information indicated that the beneficiary, of Navajo origin, suffered from multiple mental and physical health conditions. The request claims violations of various articles of the American Declaration of the Rights and Duties of Man, in relation to access to justice, due process, and adequate defense of the beneficiary, indicating that his legal defense was not appropriate or timely to avoid being sentenced to death. Moreover, Clarence Wayne Dixon is reportedly the first person executed after 8 years of suspension of this practice in the state of Arizona.
Upon analyzing the submissions of fact and law provided, the IACHR considered that the information showed prima facie that the matter met the requirements of seriousness, urgency, and irreparable harm established in Article 25 of the Rules of Procedure. Furthermore, Dixon was executed before the Commission had the opportunity to examine the merits of petition 831-22, thus any eventual decision has been rendered moot, resulting in irreparable harm.
In the precautionary measure granted, the IACHR requested that the United States of America adopt the necessary measures to protect the life and personal integrity of Clarence Wayne Dixon and refrain from carrying out the death penalty on Clarence Wayne Dixon, until the IACHR has had the opportunity to reach a decision on his petition. Similarly, the Commission required that the State ensure that Clarence Wayne Dixon's detention conditions are consistent with international standards, giving special consideration to his disabilities and medical condition; and, lastly, agree on the measures to be adopted with the beneficiary and his representatives.
In this context, the IACHR recalls that the nature of the precautionary measures granted was intended to preserve Mr. Dixon's legal situation while his case was being considered by the IACHR. Precautionary measures aim to safeguard the rights at risk until the petition pending before the inter-American system is resolved. Their object and purpose are to ensure the integrity and effectiveness of an eventual decision on the merits and, thus, avoid any further infringement of the rights at issue, a situation that may adversely affect the useful effect of the final decision. In this sense, the precautionary measures would allow not only to avoid irreparable harm to Mr. Dixon, but also that the State concerned could comply with the final recommendations made by the IACHR.
The IACHR reiterates the recommendations it made in its report "The Death Penalty in the Inter-American Human Rights System: from Restrictions to Abolition," which seek to abolish the death penalty or, failing that, to implement moratoriums on executions as a step toward the gradual disappearance of this penalty.
A principal, autonomous body of the Organization of American States (OAS), the IACHR derives its mandate from the OAS Charter and the American Convention on Human Rights. The Inter-American Commission has a mandate to promote respect for and to defend human rights in the region and acts as a consultative body to the OAS in this area. The IACHR is composed of seven independent members who are elected by the OAS General Assembly in their personal capacity, and do not represent their countries of origin or residence.