IACHR submits case to IA Court concerning enforced disappearance of individual of African descent in Brazil

December 29, 2025

Washington, DC—On October 18, 2025, the Inter-American Commission on Human Rights (IACHR) referred Case 12.859 to the Inter-American Court of Human Rights (IA Court). The case concerns the enforced disappearance of Jurandir Ferreira de Lima and the lack of an effective investigation into the events.

The IACHR received the petition in January 2007, in which it is alleged that Jurandir Ferreira de Lima, a 30-year-old man of African descent, was the president of the Residents’ Association of Vilage Pavuna, Rio de Janeiro. On March 14, 1995, he left his home to go to the Residents’ Association and never returned. Witnesses reported that he was detained by police officers and allegedly killed, although his whereabouts remain unknown. Members of his family were threatened when they attempted to search for him, and the initial complaint filed with the 31st Police Station of Ricardo de Albuquerque did not lead to an effective investigation.

The IACHR found that all the available information points to the disappearance being carried out with the involvement of State agents. Moreover, the victim’s whereabouts have never been clarified, such that the case meets the requirements for enforced disappearance under international standards. The IACHR observed that the State failed to present an alternative hypothesis based on a diligent and effective investigation, nor did it take immediate action to locate Jurandir Ferreira de Lima or identify those responsible for his disappearance.

The IACHR noted that action was only taken belatedly and in a fragmented manner. Between 2004 and 2007, witness statements were collected, but no effective proceedings were initiated. In 2014, more than 20 years after the events, the Public Prosecutor’s Office closed the case due to a lack of evidence, without clarifying Jurandir Ferreira de Lima’s whereabouts or holding anyone accountable.

The IACHR also indicated that Brazil has not fully included the crime of enforced disappearance as defined under international standards in its domestic legislation, thereby failing to comply with its obligations under domestic and international law. It further emphasized that Juradinr Ferreira de Lima’s work as a community leader and human rights defender exposed him to heightened risk, and that the impunity surrounding his case sends a message of tolerance toward violence against human rights defenders.

Based on these considerations, the IACHR concluded that the Brazilian State is responsible for violations of articles 3, 4, 5, 8(1), 13, 16, and 25(1) of the American Convention on Human Rights, in relation to articles 1(1) and 2 thereof, as well as article I(a), (b), and (d) of the Inter-American Convention on Forced Disappearance of Persons, as of February 3, 2014, the date on which Brazil ratified that treaty.

In light of these findings, the IACHR asked the IA Court to order the following measures of reparation:

1. Provide full reparation for the violations listed above, including financial compensation and measures of satisfaction.
2. Provide physical and mental health care to the victim’s family members, should they so choose, in consultation with them.
3. Investigate Jurandir Ferreira de Lima’s whereabouts and fate and return his remains to his family, if applicable.
4. Conduct a diligent and effective criminal investigation to identify those responsible for the violations.
5. Criminalize forced disappearance according to Inter-American standards.
6. Implement measures of nonrepetition, including strengthening the capacities of authorities to investigate disappearances, ensuring that adequate logistic and scientific resources are available, and providing training on international standards and the Guiding Principles for the Search for Disappeared Persons.

The Inter-American Commission on Human Rights (IACHR) is a principal and autonomous organ of the Organization of American States (OAS), whose mandate derives from the OAS Charter and the American Convention on Human Rights. Its mission is to promote and defend human rights throughout the Americas and to serve as an advisory body to the OAS in this area. The IACHR consists of seven independent members elected by the OAS General Assembly who serve in a personal capacity and do not represent their countries of origin or residence. 

No. 283/25

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