Mesures Conservatoires

Résolution No. 9/26
MC 209-25 - Rodrigo Bruno Arcángel, Olvier Bruno Palacios, Evertz Antonio Bruno Palacios and Tony Alberto Bruno Smith, Nicaragua

On February 4, 2026, the IACHR granted precautionary measures in favor of Rodrigo Bruno Arcángel, Olvier Bruno Palacios, Evertz Antonio Bruno Palacios, and Tony Alberto Bruno Smith, after considering that they are in a serious and urgent situation posing a risk of irreparable harm to their rights in Nicaragua. The beneficiaries are indigenous persons deprived of liberty. They have been subjected to death threats and assaults, under constant surveillance and limitations to express themselves in their indigenous language, in addition to inadequate conditions of detention. The foregoing is purportedly generating impacts on their physical and mental health, without receiving adequate and timely medical care. For its part, the State did not provide information on the current situation of the beneficiaries. After analyzing the available information, the Commission considered that the beneficiaries are under conditions of detention that put their rights at risk, having a differentiated impact on their particular situation as indigenous persons. Consequently, the Commission requests that Nicaragua:

  1. take 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. implement the necessary measures to ensure that the beneficiaries’ conditions of detention are compatible with the applicable international standards on the matter, including:
    1. guarantee they are not subjected to threats, intimidation, harassment, or aggression within the prison;
    2. ensure they are not subjected to reprisals for speaking their indigenous language among themselves or during family visits;
    3. ensure immediate access to quality food in sufficient quantities to meet nutritional needs, as well as continuous access to sufficient potable water; and
    4. immediately conduct a comprehensive medical evaluation of their physical and mental health, guaranteeing timely and specialized medical care and treatment, and sharing the results with their families and representatives;
  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 this resolution, so as to prevent such events from reoccurring.

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Résolution No. 8/26( EXTENSION ET SUIVI )
MC 440-25 - Andreina Baduel and Margareth Baduel, Venezuela

On January 25, 2026, the Inter-American Commission on Human Rights (IACHR) adopted Follow-up and Extension Resolution 8/2026 in relation to the situation of Andreina Baduel and Margareth Baduel. The information provided indicates that the beneficiaries carry out human rights defense activities through the Committee for the Freedom of Political Prisoners in Venezuela (Comité de Familiares y Amigos por la Libertad de los Presos Políticos, CLIPPVE) and are allegedly being subjected to harassment and threats. Upon analyzing the submissions of fact and law, in accordance with Article 25 of its Rules of Procedure, the Commission concluded that Andreina Baduel's situation persists and considered that it extends to her sister, Margareth Baduel. Accordingly, it decided:

  1. Continue to monitor the situation of Andreina Baduel, in accordance with Resolution No. 44/2025;
  2. Extend the precautionary measures in favor of Margareth Fabianna Baduel Oyoque and require that the State:
    1. adopt the necessary measures to protect the rights to life and personal integrity of Margareth Fabianna Baduel Oyoque;
    2. ensure that the appropriate measures are taken to guarantee that the beneficiary can continue to carry out her human rights defense activities without being subjected to threats, harassment, or acts of violence in the exercise thereof. In particular, the State must ensure that state actors respect the beneficiary’s rights and personal integrity in accordance with the standards established by international human rights law, and in relation to acts of risk attributable to third parties;
    3. consult and agree upon the measures to be adopted with the beneficiary and her representation; and
    4. report on the actions taken to investigate the alleged facts that led to this extension of the precautionary measures, so as to prevent such events from reoccurring.

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Résolution No. 7/26
MC 1242-25 - Yosvany Rosell García Caso, Cuba

On January 21, 2026, the IACHR granted precautionary measures on behalf of Yosvany Rosell García Caso, after considering that he is in a serious and urgent situation, given that his rights to life, personal integrity, and health are at risk of irreparable harm in Cuba.

According to the request, the beneficiary was deprived of his liberty after participating in the demonstrations of July 11, 2021, in Cuba. The request questions the lack of adequate medical care, the precarious conditions of his detention, and the impossibility of accessing medical documentation on the beneficiary’s situation. For its part, the State did not provide information to the IACHR. Under these circumstances, based on Article 25 of the Rules of Procedure, the Commission requests that Cuba:

  1. adopt the necessary measures to protect the rights to life, personal integrity, and health of Yosvany Rosell García Caso;
  2. implement the necessary measures to ensure that the beneficiary’s detention conditions are compatible with the applicable international standards on the matter;
  3. immediately carry out a comprehensive medical evaluation of his physical and mental health, and guarantee timely and specialized medical care and treatment, making the results known to his family members and representatives;
  4. ensure immediate access to quality food in a sufficient quantity to meet nutritional needs, as well as to potable water in sufficient quantity and on a continuous basis;
  5. consult and agree upon the measures to be implemented with the beneficiary and his representatives; and
  6. report on the actions taken to investigate the alleged facts that gave rise to this resolution, so as to prevent such events from reoccurring.

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Résolution No. 6/26
MC 1583-25 - Elmer Antonio Escobar González, Le Salvador

On January 19, 2026, the Inter-American Commission on Human Rights (IACHR) adopted Resolution 6/2026, granting precautionary measures on behalf of Elmer Antonio Escobar González, after considering that he is in a serious and urgent situation, given that his rights to life and personal integrity are at risk of irreparable harm in El Salvador.

According to the request, the beneficiary is a Salvadoran citizen who was deported from the United States. Upon his arrival in El Salvador, he was deprived of his liberty and is currently being held incommunicado, without his family or lawyers having any knowledge of his conditions of detention, his legal situation, or his state of health, despite the actions taken at the domestic level. For its part, the State emphasized its diligent efforts in the search, as the reports responding to the Commission account for the beneficiary’s whereabouts, and considered that the request does not meet the standards of proof and specificity required by the IACHR Rules of Procedure.

After analyzing the factual and legal allegations, the Commission considers that, at present, the beneficiary is being held incommunicado from his family and legal representatives, who have no way of directly ascertaining his legal situation, conditions of detention, or state of health. This situation has continued despite internal actions taken in the country before various judicial and administrative institutions.

Under these circumstances, based on Article 25 of the Rules of Procedure, the Commission requests that El Salvador:

  1. adopt the necessary measures to protect the rights to life and personal integrity of Elmer Antonio Escobar González;
  2. clarify the legal situation of the beneficiary. In particular, formally indicate whether the beneficiary has been charged with any crime and/or whether he has been brought before the appropriate judicial authority;
  3. implement the necessary measures to ensure that the conditions of detention of the beneficiary comply with international standards. Specifically, that the situation of prolonged incommunicado detention be ended; that regular contact with and access to his relatives, lawyers, and representatives be guaranteed as a means of safeguarding his rights;
  4. consult and agree upon the measures to be adopted with the beneficiary and his representatives; and
  5. report on the actions taken to investigate the alleged facts that gave rise to this resolution, so as to prevent such events from reoccurring.

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Résolution No. 5/26
MC 1709-25 - Duannis Dabel León Taboada and Yenisey Taboada Ortíz, Cuba

On January 19, 2026, the IACHR granted precautionary measures on behalf of Duannis Dabel León Taboada and Yenisey Taboada Ortíz, after considering that they are in a serious and urgent situation, given that their rights to life, personal integrity, and health are at risk of irreparable harm in Cuba.

According to the request, Duannis Dabel León Taboada was deprived of his liberty on July 16, 2021, after participating in the protests that took place in Cuba in 2021. To date, he has been subjected to acts of violence, lack of medical care, and precarious conditions of detention. Meanwhile, his mother, Yenisey Taboada Ortíz, has been receiving threats from state agents. For its part, the State did not provide information to the IACHR. Under these circumstances, based on Article 25 of the Rules of Procedure, the Commission requests that Cuba:

  1. take the necessary measures to protect the rights to life, personal integrity, and health of Duannis Dabel León Taboada and Yenisey Taboada Ortíz;
  2. implement the necessary measures to ensure that the conditions of detention of Duannis Dabel León Taboada are compatible with applicable international standards in this area;
  3. immediately conduct a comprehensive medical assessment of Duannis Dabel León Taboada’s physical and mental health and guarantee timely and specialized medical care and treatment, informing the results to his family and representatives;
  4. ensure that Duannis Dabel León Taboada is not subjected to violence, threats, intimidation, or aggression within the prison;
  5. take the necessary measures, with a gender-based approach, to ensure that Yenisey Taboada Ortíz can carry out her activities as a human rights defender without being subjected to threats, harassment, intimidation, or other acts of violence in the exercise of her duties;
  6. consult and agree upon the measures to be implemented with the beneficiaries and their representatives; and
  7. report on the actions taken to investigate the alleged facts that gave rise to this resolution, so as to prevent such events from reoccurring.

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Résolution No. 4/26( EXTENSION ET SUIVI )
MC 73-24 - Members of the La Plata Bahía Málaga Community Council, Colombie

On January 19, 2026, the IACHR adopted Follow-up and Extension Resolution No. 4/2026 regarding the situation of the members of the La Plata Bahía Málaga Community Council in Colombia. The IACHR analyzed the ongoing risk to the members of the Community Council located in Buenaventura, Valle del Cauca, and observed that the context of violence has intensified, characterized by the presence and territorial disputes between various illegal armed groups, which exercise control through threats, extortion, harassment, and acts of violence. The Commission noted the strategy of these groups, aimed at controlling maritime mobility, which is central to community life, and expressed concern about the murder of Alan Valencia, a young member of the Community Council. The IACHR appreciated the efforts made by the State to implement protection measures such as consultation and follow-up meetings and a workshop on collective risk. However, it considered that the risk persists and that it is necessary to strengthen actions and reinforce protection measures. In accordance with Article 25 of its Rules of Procedure, the Commission requested that Colombia:

  1. Strengthen the implementation of the necessary measures to effectively protect the life and personal integrity of the beneficiaries identified in Resolution 19/2024;
  2. Extend the precautionary measures in favor of all members of the La Plata Bahía Málaga Community Council and adopt the necessary and culturally appropriate measures to safeguard the life and personal integrity of the beneficiaries. In particular, those of a collective nature that allow for the effective security of the members of the Community Council;
  3. Implement the necessary protective measures so that beneficiaries can continue to carry out their activities in defense of human rights without being subjected to threats, intimidation, harassment, or acts of violence;
  4. Consult and agree upon the measures to be adopted with the beneficiaries and/or their representatives; and
  5. Report on the actions taken to investigate the alleged facts that gave rise to this precautionary measure, so as to prevent such events from reoccurring.

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Résolution No. 3/26
MC 1846-25 - Huascar González Rodríguez, Nicaragua

On January 10, 2026, the IACHR granted precautionary measures in favor of Huascar González Rodríguez, after considering that he is in a serious and urgent situation presenting a risk of irreparable harm to his rights in Nicaragua. It was alleged that the beneficiary, who is a lawyer and notary, was detained on October 7, 2025, and since then there has been no official information about him. Since his detention, his family members have not been informed of the charges against him or the reason for his detention; they have not been able to see him or receive information about his situation and are completely unaware of his physical and mental health and where he is being held. The Commission also noted that the State did not provide any information regarding the measures taken to address the beneficiary’s risk and locate him. 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 the beneficiary, in order to protect his rights to life and personal integrity;
  2. detail whether the beneficiary is in the custody of the State, the circumstances, and his detention conditions. In particular, disclose the place of his detention, and allow access to his legal representatives and family; and
  3. report on the actions taken 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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Résolution No. 2/26
MC 1892-25 - José Luis Subero Reyes, Venezuela

On January 9, 2026, the IACHR granted precautionary measures on behalf of José Luis Subero Reyes, after considering that he is in a serious and urgent situation, given that his rights to life, personal integrity, and health are at risk of irreparable harm in Venezuela.

According to the request, the beneficiary is a personnel analyst at the Andrés Gutiérrez Solís Hospital and a human rights activist. Since November 25, 2025, his whereabouts, legal status, and current health condition are unknown. For its part, the State did not provide information to the IACHR. Under these circumstances, based on Article 25 of the Rules of Procedure, the Commission requests that Venezuela:

  1. adopt the necessary measures to protect the rights to life, personal integrity, and health of José Luis Subero Reyes. In particular:
    1. report whether the beneficiary is in the custody of the State and, if so, indicate the reason and circumstances of his detention; or, the measures taken to determine his whereabouts or fate;
    2. if the beneficiary is in the custody of the State, indicate whether he has been charged with crimes and whether he has been brought before a competent court to review his detention, if so, expressly mention the court that hears his criminal case, or if he has not appeared before a court, clarify the reason why he has not done so;
    3. facilitate the beneficiary’s communication with his family, representatives, and trusted attorneys, and give them full access to his judicial file, if any;
    4. immediately conduct a medical assessment of his health condition and ensure timely and specialized medical care and treatment, informing his family members and representatives of the results;
  2. adopt the necessary measures to ensure that the beneficiary can carry out his activities as a human rights defender without being subjected to threats, harassment, intimidation, or acts of violence; and
  3. 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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Résolution No. 1/26
MC 1904-25 - Fernando Enrique Orozco Cassiani, his family unit, and Carolina Briceño, Venezuela

On January 9, 2026, the IACHR granted precautionary measures to Fernando Enrique Orozco Cassiani, Dilia Margarita Castillo Jiménez de Orozco, Brayant Fernando Orozco Castillo, Luz María Cassiani Villa, and Carolina Briceño, after considering that they are in a serious and urgent situation, given that their rights to life, personal integrity, and health are at risk of irreparable harm in Venezuela.

According to the request, Fernando Enrique Orozco Cassiani is a former deputy of the National Assembly. On November 25, he, his wife, his son, and his ex-partner were allegedly detained by state officials, and their whereabouts have been unknown since then. Meanwhile, his mother has reportedly been threatened by those officials. For its part, the State did not provide any information to the IACHR. Under these circumstances, based on Article 25 of the Rules of Procedure, the Commission requests that Venezuela:

  1. adopt the necessary measures to protect the rights to life, personal integrity, and health of Fernando Enrique Orozco Cassiani, Dilia Margarita Castillo Jiménez de Orozco, Brayant Fernando Orozco Castillo, Luz María Cassiani Villa, and Carolina Briceño;
  2. report whether Fernando Enrique Orozco Cassiani, Dilia Margarita Castillo Jiménez de Orozco, Brayant Fernando Orozco Castillo, and Carolina Briceño are in the custody of the State and, if so, indicate the place, reason, and circumstances of their detention; or, the measures taken to determine their whereabouts or fate;
  3. if they are in the custody of the State, implement sufficient measures to ensure that the detention conditions of Fernando Enrique Orozco Cassiani, Dilia Margarita Castillo Jiménez de Orozco, Brayant Fernando Orozco Castillo, and Carolina Briceño are compatible with applicable international standards. In particular, the following:
    1. facilitate communication with their family members, representatives and trusted lawyers, giving them full access to the judicial file, if any;
    2. indicate whether they have been charged with crimes and whether they have been brought before a competent court to review their detention, if so, expressly mention the court that has oversight of their criminal cases, or if they have not appeared before a court, clarify the reason why they have not done so;
    3. immediately carry out a medical assessment on their health situation, and guarantee timely and specialized medical care and treatment, informing their family members and representatives of the results;
  4. take the necessary measures to ensure that Luz María Cassiani Villa is not subjected to threats, harassment, intimidation or acts of violence; and
  5. 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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