58 May 3, 1994, and there sentenced Mr. Alejandro Astorga Valdez to life imprisonment as well. The lower court rulings also stipulated the terms of the incarceration, which included “continuous confinement to cell for the first year of incarceration, and then forced labor, which sentences they [the alleged victims] are to serve in solitaryconfinement cells chosen by the Director of the National Bureau of Prisons.” 194. The Court has held that “prolonged isolation and deprivation of communication are in themselves cruel and inhuman punishment, harmful to the psychological and moral integrity of the person and a violation of the right of any detainee to respect for his inherent dignity as a human being.”105 195. The Court has also ruled that under “Article 5(2) of the Convention, every person deprived of her or his liberty has the right to live in detention conditions compatible with her or his personal dignity, and the State must guarantee to that person the right to life and to humane treatment. Consequently, since the State is the institution responsible for detention establishments, it is the guarantor of these rights of the prisoners.”106 Incommunicado detention is considered to be an exceptional method of confinement because of the grave effects it has on persons so confined. “Isolation from the outside world produces moral and psychological suffering in any person, places him in a particularly vulnerable position, and increases the risk of aggression and arbitrary acts in prison.”107 196. In the Loayza Tamayo Case, the Court ruled that: The violation of the right to physical and psychological integrity of persons is a category of violation that has several gradations and embraces treatment ranging from torture to other types of humiliation or cruel, inhuman or degrading treatment with varying degrees of physical and psychological effects caused by endogenous and exogenous factors (...) The degrading aspect is characterized by the fear, anxiety and inferiority induced for the purpose of humiliating and degrading the victim and breaking his physical and moral resistance.108 197. In that same case, the Court held that: Any use of force that is not strictly necessary to ensure proper behavior on the part of the detainee constitutes an assault on the dignity of the person […], in violation of Article 5 of the American Convention. The exigencies of the investigation and the undeniable difficulties encountered in the anti-terrorist struggle must not be allowed to restrict the protection of a person’s right to physical integrity. The Court added that “incommunicado detention, […] solitary confinement in a tiny cell with no natural light, […] a restrictive visiting schedule […] all constitute forms of 105. Velásquez Rodríguez Case, supra note 19, para. 156; Godínez Cruz Case, supra note 19, para. 164; Fairén Garbi and Solís Corrales Case, supra note 19, para. 149. 106. Neira Alegría et al. Case, supra note 104, para. 60. 107. Suárez Rosero Case, supra note 80, para. 90. 108. Cf. Case of Ireland v. the United Kingdom, Judgment of 18 January 1978, Series A No. 25. para. 167 DE L; and Loayza Tamayo Case, supra note 4, para. 57.

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