In this case, Colombian Military Forces murdered Germán Escué Zapata, a leader in the indigenous Paez or Nasa community in 1988. Interestingly, the State acknowledged international responsibility for violating Articles 4(1) (Prohibition of Arbitrary Deprivation of Life), 5 (Right to Humane Treatment), and 7 (Right to Personal Liberty) in relation to Article 1(1) (Obligation to Respect Rights) of the American Convention on Human Rights. In the Court’s decision, it discussed whether violations of Article 1(1) (Obligation to Respect Rights) may be invoked separately from violations of other Articles of the Convention, and found that killing a community leader is not, per se, a violation of Article 23 (Right to Participate in Government).
Escué-Zapata v. Colombia,
36 Loy. L.A. Int'l & Comp. L. Rev. 199
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