Precautionary Measures

Resolution No. 51/23
PM 308-23 - Jonatan Alberto Palacios Castillo, Venezuela

On September 17, 2023, the IACHR decided to grant precautionary measures in favor of Jonatan Alberto Palacios Castillo, after considering that he is in a serious and urgent situation presenting a risk of irreparable harm to his rights in Venezuela. The request alleges that the beneficiary is at risk due to the lack of adequate and timely medical attention during preventive detention, despite repeated judicial decisions in his favor.

According to the applicant, the beneficiary is a Colombian citizen and is being held in pretrial detention at the Western Penitentiary Center II, without receiving the adequate and timely medical attention he purportedly requires. The Commission found that, throughout his detention period, several judicial decisions ordering his medical transfer have not been executed. The foregoing, despite the health condition of the proposed beneficiary, which reportedly led to the fact that to date his medical treatment has not been defined according to his medical condition, with pending assessments to be made.

Upon analyzing the available information, the Commission considered that compliance with the requirements contained in Article 25 of its Rules of Procedure was sufficiently justified. Therefore, it requested that Venezuela:

1. adopt the necessary measures to protect the rights to life, personal integrity, and health of Jonatan Alberto Palacios Castillo. In particular, ensuring that he has access to timely medical treatment. This includes, inter alia, making the pertinent medical transfers for the corresponding medical evaluations and follow-ups;
2. consult and agree upon the measures to be adopted with the beneficiary and his representatives; and
3. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 49/23
PM 509-23 - Lovely Lamour, Haiti

On August 29, 2023, the IACHR decided to grant precautionary measures in favor of Lovely Lamour, after considering that she is in a serious and urgent situation placing her at risk of irreparable harm to her rights in Haiti. The request alleges that the proposed beneficiary is an 18-year-old postpartum woman who is deprived of her liberty at the Port-au-Prince Police Station, without receiving medical attention appropriate to her vulnerable condition. According to the information provided, the proposed beneficiary was detained pregnant and did not receive any type of pre- and post-natal care, even though the prison facility and the judicial authorities had been informed of a case of infection. Moreover, the request alleged that the newborn died one month after spending fifteen days in the hospital with oxygen, separated from the mother. It was alleged that this whole process has generated mental affectations in the proposed beneficiary, who also does not receive psychological assistance. Upon analyzing the available information, the Commission considered that the proposed beneficiary is reportedly exposed to a multiplicity of risk sources, likely to seriously affect her rights to life, personal integrity and health, for which reason compliance with the requirements contained in Article 25 of its Rules of Procedure was sufficiently justified. After requesting information from the State, the Commission did not receive a response, as the deadlines had expired. Therefore, it requested that Haiti:

1. adopt the necessary measures to protect the rights to life, personal integrity, and health of Lovely Lamour, with a gender perspective, in accordance with applicable international standards and obligations. In particular, ensuring that she has access to medical treatment, as indicated by the corresponding physicians, and that the authorities prepare a medical report that corroborates the current health situation of the beneficiary;
2. adopt the necessary measures to bring her conditions of detention into line with applicable international standards;
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 these precautionary measures, so as to prevent such events from reoccurring.

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Resolution No. 48/23
PM 574-23 - Cesar Bernardo Arévalo de León and Karin Herrera Aguilar, Guatemala

On August 24, 2023, the IACHR granted precautionary measures in favor of Cesar Bernardo Arévalo de León and Karin Herrera Aguilar, who represent the presidential binomial elected in accordance with the preliminary results of the Supreme Electoral Tribunal, after considering that they are in a serious and urgent situation placing them at risk of irreparable harm to their rights in Guatemala. The request for precautionary measures alleged that Cesar Bernardo Arévalo de León and Karin Herrera Aguilar are purportedly subjected to stigmatization, harassment, stalking, public exposure of their personal information through virtual platforms, as well as threats that include the existence of two plans to attack their lives and integrity, one even notified by prosecutors. The Commission took into account the alleged facts in light of the context it has been monitoring in Guatemala, and assessed the actions implemented by the State. However, it noted with concern the information about at least one possible plan against the life and integrity of the two beneficiaries, which was formally notified by members of the Public Ministry, without information on the actions taken in this regard. In accordance with Article 25 of the Rules of Procedure, the Commission requests that Guatemala:

1. adopt the necessary measures to protect the rights to life and personal integrity of Cesar Bernardo Arévalo de León and Karin Herrera Aguilar in light of the assessments of this resolution;
2. consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
3. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 47/23
PM 404-23 - Members of Honduran Alternative for Community and Environmental Vindication (ARCAH), Honduras

On August 20, 2023, the IACHR granted precautionary measures in favor of 11 members of Honduran Alternative for Community and Environmental Vindication (ARCAH), after considering that they are in a serious and urgent situation that places them at risk of irreparable harm to their rights in Honduras. The request for precautionary measures alleged that ARCAH members carry out activities in the defense of environmental rights, making complaints about industrial and extractive projects and are allegedly being subject to surveillance, monitoring, intimidation, threats, and other events that place them at risk in the exercise of their work. It is also pointed out that, despite having protection measures in place, these are not being properly implemented, which has allowed for the ongoing and permanent risk to the detriment of the members of ARCAH. Such situations have purportedly remained over time and are said to have increased during 2023. Pursuant to Article 25 of the Rules of Procedure, the Commission requests that Honduras:

1. adopt the necessary measures to protect the rights to life and personal integrity of the eleven members of ARCAH;
2. adopt the necessary measures so that the beneficiaries can continue to carry out their activities as environmental rights defenders, without being subjected to threats, harassment and other acts of violence in the exercise of their 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 the adoption of this precautionary measure, so as to prevent them from reoccurring.

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Resolution No. 46/23
PM 646-23 - Christian Gustavo Zurita Ron et al., Ecuador

On August 20, 2023, the IACHR decided to grant precautionary measures in favor of Christian Gustavo Zurita Ron and identified members of his campaign team. According to the request, the proposed beneficiary is a journalist and replaced Fernando Villavicencio, then presidential candidate of the same party, who was assassinated on August 9, 2023. Pursuant to Article 25 of its Rules of Procedure, the Commission requested that the State of Ecuador:

1. immediately adopt the necessary measures to safeguard the life and personal integrity of Christian Gustavo Zurita Ron and the persons in his campaign team duly identified in this resolution;
2. adopt the necessary measures so that Christian Gustavo Zurita Ron can carry out his journalistic activities in exercise of his right to freedom of expression, without being subjected to acts of intimidation, threats, or other acts of violence;
3. adopt the necessary measures so that Christian Gustavo Zurita Ron can carry out his activities as member of his political party, without being subjected to acts of intimidation, threats, or other acts of violence;
4. consult and agree upon the measures to be implemented with the beneficiaries and their representatives; and
5. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this precautionary measure and to avoid their repetition.

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Resolution No. 44/23
PM 99-23 - A. A. Q. O. and family, Mexico

On August 12, 2023, the IACHR decided to grant precautionary measures in favor of A. A. Q. O. and A. L. Q. O. and their family members, in Mexico. The request indicates that the beneficiary family is subject to harassment, threats, and other acts of violence, in relation to A. A. Q. O.’s work as a human rights defender and A. L. Q. O.’s status as a survivor of human trafficking. Pursuant to Article 25 of its Rules of Procedure, the Commission requested that the State of Mexico:

1. adopt the necessary measures to protect the rights to life and personal integrity of A. A. Q. O., A. L. Q. O., and their relatives. In this regard, the State should adopt protection measures with a gender perspective and other differentiated approaches that are relevant, taking into account the work in human rights defense and the status as a human trafficking survivor as a form of gender violence, in relation to the duty of reinforced due diligence;
2. consult and agree upon the measures to be adopted with the beneficiaries and their representatives, maintaining the beneficiaries’ identities confidential in a discretional manner; and
3. 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. 43/23
PM 532-23 - David Estiven Fernández Soler, Colombia

On July 28, 2023, the IACHR decided to grant precautionary measures in favor of David Estiven Fernández Soler. According to the request, the beneficiary is a young social activist and Youth Advisor of the Kennedy district and has been missing since June 7, 2023, to date. The Commission assessed the available information, and noted that, although investigations are being carried out in this regard, so far there is no information on the fate or whereabouts of David Estiven Fernandez Soler. Upon analyzing the request, the Commission was considered that the beneficiary is at imminent risk. Consequently, in accordance with Article 25 of the Rules of Procedure, the Commission requests that Colombia:

1. adopt the necessary measures to determine Mr. David Estiven Fernández Soler’s situation and whereabouts, in order to protect his rights to life and personal integrity; and
2. 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. 42/23
PM 341-23 - Gustavo Andrés Gorriti Ellenbogen, Peru

On July 24, 2023, the IACHR decided to grant precautionary measures in favor of Gustavo Andrés Gorriti Ellenbogen. According to the request, the beneficiary is the director of IDL-Reporteros and an investigative journalist, and is reportedly suffering various acts of harassment and threats -including anti-Semitic statements-, in addition to the leaking and dissemination of his personal information on social networks, as part of a stigmatization campaign known as “terruqueo”. The Commission valued the information provided by the State; however, it observed the ongoing death threats, despite the existence of permanent patrols and tactical parking at the IDL headquarters and the beneficiary's private home. Therefore, pursuant to 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 measures to protect the rights to life and personal integrity of Mr. Gustavo Gorriti;
2. adopt the necessary measures so that Gustavo Gorriti can carry out his activities without being subjected to acts of violence, intimidation, threat, or harassment in the exercise of his duties. The foregoing includes the adoption of measures so that he can duly exercise his right to freedom of expression;
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 events that led to the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 41/23
PM 196-23 - Indigenous Carib Community of Chinese Landing , Guyana

On July 21, 2023, the Inter-American Commission on Human Rights adopted Resolution 41/2023, by which it granted precautionary measures in favor of members of Indigenous Carib Community of Chinese Landing, upon considering that they are in a serious and urgent situation of the rights to life and personal integrity in Guyana. The alleged risks relate to threats, harassment and acts of violence perpetrated against the beneficiaries in the context of their opposition to mining activities carried in their lands. Consequently, in accordance with the provisions of Article 25 of its Rules of Procedure, the IACHR requested that the State of Guyana:

1. take the necessary measures to protect the rights to life and personal integrity of the members of the Indigenous Carib Community of Chinese Landing, identified as beneficiaries, with a cultural, gender-based, and age-appropriate perspective to prevent threats, harassment, and other acts of violence against the beneficiaries;
2. consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
3. report on the actions taken to investigate the events that led to the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 40/23
PM 409-23 - Franklin Alfredo Caldera Cordero, Venezuela

On July 20, 2023, the IACHR decided to grant precautionary measures in favor of Franklin Alfredo Caldera Cordero, after considering that he is in a serious and urgent situation presenting a risk of irreparable harm to his rights in Venezuela. The request alleges that the beneficiary is being subjected to acts of persecution and threats as a consequence of his work as a human rights defender and founder of the Victims Committee "Familia S.O.S. Libertad". In particular, it was indicated that the threatening events occurred as a result of public statements and denunciations regarding the situation of political prisoners in Venezuela, specifically his son, a former lieutenant of the Venezuelan Army, who has been deprived of liberty since February 11, 2021, in a cell of the DGCIM in an allegedly arbitrary manner and without receiving the necessary medical attention.

Upon analyzing the available information, the Commission considered that compliance with the requirements contained in Article 25 of its Rules of Procedure was sufficiently justified. Therefore, it requested that Venezuela:

1. adopt the necessary measures to protect the rights to life and personal integrity of Franklin Alfredo Caldera Cordero;
2. adopt the necessary protective measures so that Mr. Franklin Alfredo Caldera Cordero can continue to carry out his human rights defense work, without being subject to threats, intimidation, harassment, or acts of violence;
3. consult and agree on 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 such events from reoccurring.

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Resolution No. 39/23
PM 303-23 - Richard Moore, United States

On July 4, 2023, the Inter-American Commission on Human Rights (IACHR) issued Resolution 39/23 granting precautionary measures in favor of Richard Moore. The request indicates that Mr. Moore is at risk given the imminent execution of the death penalty. The applicants also filed a petition alleging violations of the American Declaration of the Rights and Duties of Man. Having analyzed the submissions of fact and law provided, the Commission considers that the information submitted shows prima facie that there is a serious and urgent risk of irreparable harm to Mr. Moore’s rights to life and personal integrity in accordance with Article 25 of its Rules of Procedure. Moreover, if Mr. Moore is executed before the Commission has the opportunity to examine the merits of his petition, any eventual decision would be rendered moot, leading to irreparable harm. Consequently, the Commission requests that the United States of America:

1. adopt the necessary measures to protect the life and personal integrity of Richard Moore; and
2. refrain from carrying out the death penalty on Richard Moore, until the IACHR has had the opportunity to reach a decision on his petition.

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Resolution No. 37/23
PM 438-23 - Mary Yuli González Pérez, Venezuela

On June 24, 2023, the IACHR decided to grant precautionary measures in favor of municipal councilor Mary Yuli González Pérez, in the Bolivarian Republic of Venezuela. According to the request, the proposed beneficiary is at risk as a result of threats, harassment, and acts of violence against her, as a consequence of her work as a council member and her activities as part of the political opposition. Upon analyzing the submissions of fact and law provided in the request, the IACHR considers, from the applicable prima facie standard, that Ms. Mary Yuli González Pérez is in a serious and urgent situation, given that her rights to life and personal integrity face a risk of irreparable harm. Consequently, based on Article 25 of its Rules of Procedure, the Commission requested that the Bolivarian Republic of Venezuela

1. adopt the necessary measures to protect the rights to life and personal integrity of Mary Yuli González Pérez;
2. adopt the necessary protection measures so that Ms. Mary Yuli González Pérez can continue to carry out her social and political activities, particularly in exercise of her duties as alternate Council Member to the Capital District City Council, without being subject 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 facts that gave rise to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 35/23
PM 160-23 - C.P.R and J.P.R, Argentina

On June 21, 2023, the Inter-American Commission on Human Rights adopted Resolution 35/2023, through which it granted precautionary measures to girls C.P.R. and J.P.R., upon considering that they are in a serious and urgent situation that may imply irreparable harm to the protection of the family, integrity, and identity of the beneficiaries.

According to the request, the father of C.P.R., 14 years old, and J.P.R., 12 years old, has not been able to have contact with his daughters since 2017, when a restraining order was granted for having been criminally accused of the crime of sexual abuse. Despite having been acquitted in 2018, and repeated requests before the civil judge to reunite the applicant with his daughters, the family allegedly has yet to be reunited.

The State reported on the investigation, the medical examinations carried out by the Forensic Medical Corps on the girls, the study of their situation before, during and after the complaint of sexual abuse, which led to the determination that there was no criminal responsibility of the father, ordering his dismissal since May 2018. It was also reported that the competent Court has been monitoring the situation of the girls, mainly through the evaluation of psychological reports. More recently, in July 2021, the Court reportedly ordered the children to be evaluated in order to know if it was possible to advance in the reunification.

In view of the information provided, the Commission considered that there is sufficient signs to assess that there is no relationship between the father and his daughters at present due, first, to the non-review of the restraining order issued by the competent civil Court in 2017; subsequently, due to the alleged delay in beginning to evaluate a possible reunification and relationship; and, finally, due to a series of alleged obstacles or difficulties which have impacted the father-child relationship leading to the fact that, in practice, there has been no contact between the father and his two daughters for an extended time.

Due to the foregoing, the IACHR considered that this matter meets prima facie the requirements of seriousness, urgency, and irreparable harm set forth in Article 25 of its Rules of Procedure. Consequently, the IACHR requested that Argentina adopt the necessary measures to safeguard the rights of the children C.P.R. and J.P.R. In particular, the State must immediately carry out through the competent authorities, and the relevant specialists, an assessment of the children’s current circumstances, and an evaluation of the precautionary and provisional measure issued in October 2017 by the National Civil Court of First Instance No. 87 which determines the lack of contact between the children and their biological father, taking into account current circumstances and their best interests, in accordance with international standards in the matter.

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Resolution No. 34/23
PM 304-23 - J.N.S.R., Nicaragua

On June 19, 2023, the IACHR decided to grant precautionary measures in favor of J.N.S.R., after considering that he is in a serious and urgent situation posing a risk of irreparable harm to his rights in Nicaragua. The request for precautionary measures alleged that the person identified is vice-president of the 19 April University Movement (MU19A) and has been deprived of liberty since April 4, 2023, at the Judicial Assistance Directorate, incommunicado and without official information regarding his situation, required medical care and medications, and current conditions of detention, despite suffering from a series of health problems. Pursuant to 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 J.N.S.R.;
2. adopt the necessary measures to ensure that the beneficiary’s detention conditions are compatible with the applicable international standards on this subject, inter alia: i. guaranteeing access to adequate and specialized medical care, and immediately carrying out a specialized medical evaluation of his health; ii. providing the necessary treatments and medications to treat his illnesses; and iii. guaranteeing regular contact with and access to his family members, lawyers, and representatives;
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 the adoption of this resolution, so as to prevent them from reoccurring.

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Resolution No. 33/23
PM 903-22 - David Mayorga Osorio and José Luis Moreno Álvarez, Colombia

On June 12, 2023, the Inter-American Commission on Human Rights adopted Resolution 33/2023, through which it granted precautionary measures to human rights defenders David Mayorga Osorio and José Luis Moreno Álvarez, members of the Integrated Corporation for the Defense of Human, Social, Political, Cultural, Environmental and Business Rights of Colombia (CORPOINDH), considering that their rights to life and personal integrity are at risk.

The Commission noted that the beneficiaries have been subjected to threats and constraints due to their investigations, complaints and advice to the population victim of the armed conflict and by making visible the illicit activities of different armed groups, which operate in the department of Santander and the Magdalena Medio region. Similarly, the Commission noted that, despite the existence of material protection measures, threatening situtations remain over time, and therefore it considered that the risk has continued and has not been mitigated or disappeared to date. Lastly, the Commission expressed its concern that the events faced by the beneficiaries have led them, for certain temporary moments, to have to completely stop their work of defending human rights with a view to protecting themselves.

Consequently, in accordance with the provisions of Article 25 of its Rules of Procedure, the IACHR requested that the Republic of Colombia:

1. immediately adopt the necessary measures to preserve the life and personal integrity of the identified beneficiaries;
2. adopt protection measures that allow the beneficiaries to continue carrying out their activities in defense of human rights without being subjected to threats, intimidation and acts of violence against them;
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 facts that gave rise to the adoption of the precautionary measures, so as to prevent such events from reoccurring.

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Resolution No. 30/23
PM 283-23 - Gustavo Enrique Carrero Angarita, Venezuela

On May 29, 2023, the IACHR granted precautionary measures in favor of Gustavo Enrique Carrero Angarita, upon considering that he is at serious and urgent risk of irreparable harm to his rights in Venezuela. The request for precautionary measures alleges that the proposed beneficiary, who identifies himself as Frigate lieutenant of the National Bolivarian Armed Force, is deprived of his liberty in the National Center for Accused Members of the Military (CENAPROMIL, also known as "Ramo Verde") without receiving the necessary medical attention to his health and in inadequate conditions of detention. Moreover, his situation is reportedly aggravated due to the threats and ill-treatment that he is allegedly receiving from prison officers, after being identified as a “traitor to the homeland” in Venezuela. Having analyzed the information available, the Commission considered that compliance with the requirements contained in Article 25 of its Rules or Procedure was sufficiently supported. Therefore, the IACHR requested that Venezuela:

1. adopt the necessary measures to protect the rights to life, personal integrity and health of Gustavo Enrique Carrero Angarita. In particular, ensure that he has access to medical treatment, as indicated by the relevant physicians, and order that the authorities make a medical report that corroborates the beneficiary’s current health;
2. take the necessary measures to ensure that the beneficiary’s detention conditions are compatible with the applicable international standards;
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 the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 29/23
PM 286-23 - Antonio Julio Scola Lugo, Venezuela

On May 22, 2023, the IACHR granted precautionary measures in favor of Antonio Julio Scola Lugo, upon considering that he is at serious and urgent risk of irreparable harm to his rights in Venezuela. The request for precautionary measures alleges that the proposed beneficiary, who identifies himself as lieutenant of the Venezuelan Navy, is deprived of his liberty in the National Center for Accused Members of the Military (CENAPROMIL, also known as "Ramo Verde") without receiving the necessary medical attention to his health and in inadequate conditions of detention. Moreover, his situation is reportedly aggravated due to the threats and ill-treatment that he is allegedly receiving from prison officers, after being identified as a “traitor to the homeland” in Venezuela. Having analyzed the information available, the Commission considered that compliance with the requirements contained in Article 25 of its Rules or Procedure was sufficiently supported. Therefore, the IACHR requested that Venezuela:

1. take the necessary measures to protect the rights to life, personal integrity, and health of Antonio Julio Scola Lugo. In particular, ensure that he has access to medical treatment, as indicated by the relevant physicians, and order that the authorities make a medical report that corroborates the beneficiary’s current health;
2. take the necessary measures to ensure that the beneficiary’s detention conditions are compatible with the applicable international standards;
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 the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 28/23
PM 285-23 - Carlos Gustavo Macsotay Rauseo, Venezuela

On May 16, 2023, the IACHR granted precautionary measures in favor of Carlos Gustavo Macsotay Rauseo, upon considering that he is in a serious and urgent situation presenting a risk of irreparable harm to his rights in Venezuela. The request for precautionary measures alleges that the beneficiary, who identifies himself as captain of Corvette of the Venezuelan Navy, is deprived of his liberty in the National Center for Accused Members of the Military (CENAPROMIL, also known as “Ramo Verde”) without receiving the necessary medical attention to his health and in inadequate conditions of detention. Similarly, his situation is reportedly aggravated due to the threats and ill-treatment that he is allegedly receiving from prison officers, after being identified as a “traitor to the homeland” in Venezuela. Having analyzed the information available, the Commission considered that compliance with the requirements contained in Article 25 of its Rules or Procedure was sufficiently supported. Therefore, the IACHR requested that Venezuela:

a. adopt the necessary measures to protect the rights to life, personal integrity, and health of Carlos Gustavo Macsotay Rauseo. In particular, ensure that he has access to medical treatment, as indicated by the corresponding physicians, and that the authorities prepare a medical report that verifies the beneficiary’s current health;

b. take the necessary measures to ensure that the beneficiary’s detention conditions are compatible with the applicable international standards;

c. consult and agree upon the measures to be adopted with the beneficiary and his representatives; and

d. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 27/23
PM 53-23 - Álvaro Alcides Crespo Hernández and his daughter, Colombia

On May 3, 2023, the IACHR decided to grant precautionary measures in favor of Álvaro Alcides Crespo Hernández and his immediate family members. According to the request, the beneficiary is a teacher, member of the Zenú indigenous people and governor of the La Libertad Indigenous Council in the territory of the district of Pica Pica Viejo, municipality of Puerto Libertador, department of Córdoba and would be suffering death threats from illegal armed groups since 2020. The Commission assessed the information provided by the State, however, it noted that the requesting party referred to ongoing death threats and the absence of an assessment of the situation of the proposed beneficiary for the implementation of a suitable protection detail to date. Therefore, pursuant to Article 25 of the Rules of Procedure, the IACHR decided to grant precautionary measures and requested that the State of Colombia:

1. adopt the necessary measures, with the corresponding ethnic approach, to protect the rights to life and personal integrity of Mr. Álvaro Alcides Crespo Hernández and his daughter;
2. adopt the necessary protection measures so that Mr. Álvaro Alcides Crespo Hernández can continue to carry out his leadership activities without being subject to threats, intimidation, harassment, or acts of violence;
3. consult and agree upon the measures to be implemented 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. 25/23
PM 61-23 - Members of the Pataxó Indigenous People located in the Barra Velha and Comexatibá Indigenous Lands in the state of Bahia, Brazil

On April 24, 2023, the IACHR granted precautionary measures in favor of members of the Pataxó Indigenous People located in the Barra Velha and Comexatibá Indigenous Lands in the state of Bahia in Brazil. According to the information received, the beneficiaries are in a situation of risk in the framework of conflicts related to the determination of their territory, having been the object of threats, harassment and acts of violence, including the murder of three young Pataxó men. Consequently, in accordance with Article 25 of the IACHR Rules of Procedure, Brazil is requested:

1. to adopt the necessary measures to protect the life and personal integrity of the members of the Pataxó Indigenous People as identified, including from acts perpetrated by third parties, taking into consideration the cultural relevance of the measures adopted;
2. to coordinate the measures to be adopted with the beneficiary persons and their representatives; and
3. to report on the actions taken to investigate the facts that motivated the adoption of this precautionary measure and thus prevent their repetition.

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Resolution No. 22/23
PM 176-23 - Michael Tisius, United States

On April 16, 2023, the IACHR granted precautionary measures in favor of Michael Tisius. The request indicates that Mr. Tisius is at risk given the imminent execution of the death penalty. The applicants also submitted a petition alleging violations of the American Declaration of the Rights and Duties of Man. 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 Mr. Tisius’s rights to life and personal integrity, in accordance with Article 25 of its Rules of Procedure. Furthermore, should Mr. Tisius 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 Michael Tisius; and
2. refrain from carrying out the death penalty on Michael Tisius, until the IACHR has had the opportunity to reach a decision on his petition.

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Resolution No. 20/23
PM 738-22 - D.R.Z., D.A.B.A., A.C.L. and I.C.L., Nicaragua

On April 13, 2023, the IACHR decided to grant precautionary measures in favor of 4 members of the Mayangna indigenous people, who are deprived of their liberty. According to the requesting party, the beneficiaries were sentenced for the Kiwakumbaih Massacre and have been deprived of their liberty since 2021 without receiving adequate and timely medical attention, in unhealthy conditions and being subjected to constant threats from guards and other persons deprived of their liberty. In its analysis, the Commission took into account that the facts presented have been purportedly perpetrated by State officers, which would put the beneficiaries in a special situation of vulnerability. Consequently, in accordance with Article 25 of its Rules of Procedure, the IACHR requests that Nicaragua:

1. adopt the necessary measures to protect the rights to life, personal integrity, and health of the beneficiaries, taking into account their status as members of an indigenous people;
2. adopt the necessary measures to ensure that the beneficiaries’ detention conditions are compatible with the applicable international standards in this area, including the following: i) ensuring that they are not subjected to threats, intimidation, harassment, or assault within the prison; ii) guaranteeing access to adequate and specialized medical care, and immediately carrying out a specialized medical assessment of their health; and iii) granting the necessary treatments and medications to treat their respective illnesses;
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 the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 19/23
PM 214-23 - Rolando José Álvarez Lagos, Nicaragua

On April 13, 2023, the IACHR granted precautionary measures in favor of Rolando José Álvarez Lagos, 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. Álvarez Lagos, who is a priest and bishop of Matagalpa, is being deprived of his liberty in the Jorge Navarro National Penitentiary System known as “La Modelo,” and there is no information from the state authorities about his current situation and current conditions of detention, after being incommunicado since his arrest. It was also pointed out that Mr. Álvarez Lagos suffers from a series of health problems, and there is no information about his current state of health or if he has access to medical care and the necessary medications. Pursuant to Article 25 of its Rules of Procedure, the IACHR requests that Nicaragua:

1. take the necessary measures to protect the rights to life, personal integrity, and health of Rolando José Álvarez Lagos;
2. take the necessary measures to ensure that the beneficiary’s detention conditions are compatible with the applicable international standards in the matter, including: i. guaranteeing access to adequate and specialized medical care, and immediately carry out a specialized medical evaluation of his health; ii. ensuring access to the treatments and medications required to treat his health issues; and iii. guaranteeing regular contact and access to his family members, his lawyers, and representatives;
3. consult and agree upon the measures to be adopted with the beneficiary and his representatives; and
4. report on the actions undertaken in order to investigate the alleged facts that led to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 18/23
PM 937-22 - Pedro de Jesús Pinto Cabrera and his family unit, Honduras

On April 13, 2023, the IACHR granted precautionary measures in favor of Pedro de Jesús Pinto Cabrera and his family, after considering that they are in a serious and urgent situation presenting a risk of irreparable harm to their rights in Honduras. The request for precautionary measures alleges that the proposed beneficiary is a public official of the Forest Conservation Institute and carries out environmental rights defense activities in the municipality of La Labor, in the department of Ocotepeque, in the Guisayote Reserve. Due to his work, the proposed beneficiary is reportedly subject to acts of violence, threats, and intimidation since November 2022. In its analysis, the Commission assessed the protection measures taken by the State. However, the Commission considered that the threatening events are said to be a form of retaliation against the proposed beneficiary's action in the defense of the environment, as well as the serious and ongoing risk, despite the protection measures. Accordingly, under the terms of Article 25 of the Rules of Procedure, the Commission requests that the State of Honduras:

1. adopt the necessary measures to protect the rights to life and personal integrity of Pedro de Jesús Pinto Cabrera and his family unit;
2. adopt the necessary measures so that the beneficiary can carry out his activities without being subject to threats, harassment, and violence in the exercise of his duties as a Reserve Ranger of the Directorate of the Guisayote Reserve Institute (Guarda Reserva de la Dirección del Instituto de Reserva Guisayot
3. and President of the Water Board (Junta de Agu
4. of the La Mesa neighborhood, in La Labor, Department of Ocotepeque;
5. consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
6. report on the actions taken to investigate the alleged facts that gave rise to the adoption of this precautionary measure, so as to prevent such incidents from reoccurring.

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Resolution No. 15/23
PM 66-23 - Carlos Eduardo Salazar Ojeda et al. (Trade Union Leaders of the Civil Society Organization National Trade Union Coalition of Workers), Venezuela

On April 1, 2023, the IACHR decided to grant precautionary measures in favor of seven union leaders of the Civil Society Organization National Trade Union Coalition of Workers (CSNT) in Venezuela. According to the requesting party, the beneficiaries have played a leading role in the convening of demonstrations since 2022, within the framework of the disagreement of public employees with the approval of a technical instruction by the National Budget Office (ONAPRE), for which they are said to be suffering threats, harassment, and surveillance by State agents repeatedly. In its analysis, the Commission took into account that the facts presented have been purportedly perpetrated by State officers, which would put the beneficiaries in a special situation of vulnerability. Consequently, in accordance with Article 25 of its Rules of Procedure, the IACHR requests that Venezuela:

1. adopt the necessary measures to protect the rights to life and personal integrity of the beneficiaries;
2. adopt the necessary protection measures so that the beneficiaries can continue to carry out their union leadership activities without being subject to threats, intimidation, harassment or acts of violence;
3. consult and agree upon the measures to be implemented with the beneficiaries and their representatives; and
4. report on the actions taken in order to investigate the alleged facts that led to the adoption of this resolution, so as to prevent such events from reoccurring.

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Resolution No. 12/23
PM 492-21 - Juan Carlos Soni Bulos et al., Mexico

On March 21, 2023, the Inter-American Commission on Human Rights adopted Resolution 12/2023, by which it granted precautionary measures in favor of Juan Carlos Soni Bulos et al., upon considering that they are in a serious and urgent situation of the rights to life and personal integrity in Mexico.

It was alleged that in the context of the safety issues within the Huasteca area, there are violent acts specifically directed against Juan Carlos Soni Bulos, his family members, and close colleagues. This situation has reportedly persisted over time. The Commission assessed the intensification of recent threats, harassment, and/or acts of violence allegedly carried out by organized armed groups, and which have been brought to the attention of the Protection Mechanism. In addition, the Commission considered that, regarding Juan Carlos Soni and three other beneficiaries, the State has maintained protection measures for a period of eight years, regardless of their origin or relationship with the defense of human rights. Moreover, the IACHR assessed the scope of the protection measures implemented by the State, however, they are reportedly not mitigating or reducing the risk factors. Consequently, in accordance with the provisions of Article 25 of its Rules of Procedure, the IACHR requested that the State of Mexico:

1. Immediately adopt the necessary measures to preserve the life and personal integrity of the duly identified beneficiaries;
2. Consult and agree upon the measures to be adopted with the beneficiaries and their representatives; and
3. Report on the actions taken to investigate the alleged facts that led to the adoption of these precautionary measures.

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Resolution No. 11/23
PM 41-22 - Hedme Fátima Castro Vargas and her family unit, Honduras

On March 6, 2023, the IACHR granted precautionary measures in favor of Hedme Fátima Castro Vargas and her family unit, after considering that they are in a serious and urgent situation posing a risk of irreparable harm to their rights in Honduras. In the request for precautionary measures, it is alleged that Hedme Fátima Castro Vargas, who is a human rights defender and executive director of the Association for Participatory Citizenship (ACI-PARTICIPA), is being subjected to monitoring, surveillance, threats, and other threatening events in the exercise of her duties. In the request, it is also pointed out that despite having current protection measures in place, these are not being adequately implemented nor have corresponding corrective actions been taken to the date, which has allowed the ongoing and permanent threatening situation to the detriment of Ms. Hedme Fátima Castro Vargas and her family members. Therefore, the State of Honduras is requested to:

1. adopt the necessary measures, with a gender approach, to protect the rights to life and personal integrity of Ms. Hedme Fátima Castro Vargas and the members of her family unit;
2. adopt the necessary protective measures, with the corresponding gender approach, in order for Ms. Hedme Fátima Castro Vargas to continue carrying out her activities in defense of human rights without being subject to threats, intimidation, harassment, and acts of violence;
3. consult and agree upon the measures to be implemented 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. 10/23
PM 938-22 - Members of the Boa Hora III/Marmorana Quilombola Territory, located in the rural area of Alto Alegre do Maranhão, in the State of Maranhão, Brazil

On February 27, 2023, the IACHR decided to grant precautionary measures in favor of members of the traditional Afro-descendant Quilombola people of the Boa Hora III/Marmorana Quilombola Territory, in the state of Maranhão, in Brazil. According to the request, a landowner invaded part of the territory, tore down the fences of the residents, surrounded the community’s plantation areas, and prevented access to the natural source of water used by the community. The above, allegedly with the use of armed men, who would be monitoring and threatening the beneficiaries. The Commission appreciated the information provided by the State; however, it observed that the applicants have referred to the continued presence of armed men in the community, intimidation actions against the beneficiaries, and the absence of collective protection measures adopted by the State. 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 Brazil:

1. adopt the necessary and culturally appropriate measures, with a due ethnic-racial approach, to protect the rights to life and personal integrity of the members of the Boa Hora III/Marmorana Quilombola Territory. Similarly, the State must guarantee that the rights of the beneficiaries are respected in accordance with the standards established by international human rights law, with respect to threatening acts attributable to third parties;
2. consult and agree upon the measures to be adopted with the beneficiaries and/or their representatives; and
3. report on the actions taken to investigate the facts that gave rise to the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 5/23
PM 729-22 - Liz Patricia Benavides Vargas and her family unit, Peru

On February 6, 2023, the Inter-American Commission on Human Rights adopted Resolution 5/2023, by which it granted precautionary measures in favor of de Liz Patricia Benavides Vargas and her family unit. The IACHR considered the current context of institutional crisis in the country, as well as the investigations she is carrying out as Attorney General.

The Commission also acknowledged and appreciated that the State is providing material protection to the proposed beneficiary and that it has even increased the personnel that make up her security detail within the framework of domestic provisions. However, given the situation raised, these personnel are said to be insufficient, and their increase has been allegedly denied.

Consequently, pursuant to Article 25 of its Rules of Procedure, the IACHR requested that the State of Peru:

1. adopt the necessary measures to guarantee the rights to life and personal integrity of the 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. 4/23
PM 931-22 - Guillermo Andrés Mosquera Miranda et al., Colombia

On February 6, 2023, the IACHR decided to grant precautionary measures in favor of Guillermo Andrés Mosquera Miranda, Nidia Marcela Montoya, Carlos Mauricio Mosquera Miranda and their families. Guillermo Andrés Mosquera Miranda and his partner, Nidia Marcela Montoya, are teachers in the department of Cauca and peasant social leaders. Carlos Mauricio Mosquera Miranda, was a candidate for the House of Representatives of the legislative elections for the jurisdiction of peace during 2022. According to the request, the beneficiaries have suffered death threats from illegal armed groups, were victims of forced displacement and were subjected to acts of violence. The Commission appreciated the actions taken by the State and the information available; however, it noted that the applicants have referred to the ongoing threats from illegal armed groups and the lack of protective measures taken by the State. Therefore, in the terms of Article 25 of its Rules of Procedure, the IACHR decided to grant the precautionary measure and requested that the State of Colombia:

1. adopt the necessary measures to protect the life and personal integrity of Carlos Mauricio Mosquera Miranda, Guillermo Andrés Mosquera Miranda, Nidia Marcela Montoya, and their family units;
2. adopt the necessary measures to ensure that the beneficiaries can continue to carry out their activities as human rights defenders without being subjected to threats, intimidation, harassment, or acts of violence;
3. consult and agree upon the measures with the beneficiaries and their representatives; and
4. report on the actions taken to investigate the alleged events that led to the adoption of these precautionary measures, so as to prevent such events from reoccurring.

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Resolution No. 3/23
PM 892-22 - Pascuala López López and her family unit , Mexico

On January 26, 2023, the Inter-American Commission on Human Rights adopted Resolution 3/2023, through which it granted precautionary measures for the benefit of Pascuala López López and her family unit.

The Commission considered that the existence of a situation entailing a serious risk to the beneficiary’s rights to life and personal integrity related to her position regarding the elections of authorities in the ejido Cuxtitalli el Pinar, Chiapas, and on the demands for justice for the murder of her son occurred in February 2020 is sufficiently established, and that the risk events have continued to present themselves against her and her relatives. Additionally, the Commission noted that no substantive progress has been made in sanctioning those who would be responsible for the risk events, which is a relevant aspect when establishing the risk that the beneficiary would face and the likelihood of their recurrence.

Consequently, pursuant to the provisions of Article 25 of its Rules of Procedure, the IACHR requested that the State of Mexico:

1. take the necessary measures to guarantee the life and personal integrity of Ms. Pascuala López López and her identified relatives, and, specifically, ensure their safety and prevent acts of threats, intimidation, and violence against them by third parties, whilst considering the differentiated approaches based on their gender and cultural relevance;
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. 2/23
PM 876-22 - Eleven members of the Jesuit community of Cerocahui, Tarahumara, municipality of Urique, Chihuahua, Mexico

On January 22, 2023, the Inter-American Commission on Human Rights adopted Resolution 2/2023, by which it granted precautionary measures to eleven members of the Jesuit community of Cerocahui, Tarahumara, in the municipality of Urique, Chihuahua, Mexico. The Commission considered that the beneficiaries are prima facie in a situation that places them at serious risk in the face of threats and aggressions, perpetrated by a criminal group, which also prevents the normal development of their pastoral activities and support to the communities of the area. The Commission noted that the situation of the proposed beneficiaries is framed in a context of violence and insecurity that especially affects the inhabitants of the region of Tarahumara, Chihuahua, primarily after the murder of two Jesuit priests on June 20, 2022, inside their own temple. The Commission also observed that there is a context of stigmatization and delegitimization of the proposed beneficiaries after their complaints and actions linked to the investigation into the murder of Jesuit priests, and questions about their position on the security policies of the State.

Consequently, in accordance with the provisions of Article 25 of its Rules of Procedure, the IACHR requested that the State of Mexico:

1. adopt the necessary security measures to protect the life and personal integrity of the beneficiaries. Among these measures, their safety must be guaranteed and any acts of threat, intimidation, and violence against them by third parties must be prevented;
2. adopt protective measures that allow the proposed beneficiaries to continue carrying out their pastoral work without being subjected to threats, intimidation, harassment, and acts of violence against them;
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 facts that led to the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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Resolution No. 1/23
PM 42-23 - Ricardo Arturo Lagunes Gasca and Antonio Díaz Valencia, Mexico

On January 22, 2023, the IACHR decided to grant precautionary measures in favor of Ricardo Arturo Lagunes Gasca and Antonio Díaz Valencia, in Mexico. The request for precautionary measures indicates that since January 15, 2023, the whereabouts or fate of the beneficiaries is unknown. It was also reported that prior to their disappearance, both beneficiaries participated in a communal assembly in Aquila, Michoacán, a community where Ricardo Lagunes provided legal accompaniment and Antonio Díaz is a community leader. Pursuant to Article 25 of its Rules of Procedure, the Commission requested that the State of Mexico:

1. redouble the efforts to determine the whereabouts or fate of Ricardo Arturo Lagunes Gasca and Antonio Díaz Valencia, in order to protect their rights to life and personal integrity; and
2. report on the actions taken to investigate the facts that led to the adoption of this precautionary measure, so as to prevent such events from reoccurring.

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