were not illegal under the applicable law.” This principle governs the actions of all the organs of the State, within their respective competences, particularly when the time comes to exercise punitive powers.150 The Inter-American Court has also indicated that the principle of non-retroactivity is also intended to prevent an individual from being punished for an act that, when committed, was not an offense or that was not punishable or could not be prosecuted.151 Additionally, the ICourtHR has established that the application of an administrative sanction or punishment that is substantially different to that established by law violates the principle of legality, because it is based on extensive interpretations of the criminal law.152 115. Consequently, there are two additional arguments that allow us to subsume what happened with regard to the impeachment proceedings into Article 9 of the American Convention. First, it should be considered that the “principle of legality” contains not only aspects relating to the existence of a prior law and sanction that explicitly mentions the literal meaning of the principle,153 but also the guarantee of the principle of criminalization. The principle of criminalization means that the punitive law must define with sufficient detail the elements that constitute the offense.154 Thus, not only must the guarantees of due process of law be applied in impeachment proceedings, but also the need for grounds for removal that are sufficiently clear must be considered included in the principle of legality, in order to avoid or prevent the risk of abusive interpretations. 155 And, as I have 150 Cf. Case of Baena Ricardo et al. v. Panama. Merits, reparations and costs, para. 107, and Case of Fermín Ramírez v. Guatemala. Merits, reparations and costs, para. 90; Case of Mohamed v. Argentina, para. 130. 151 Cf. Case of Ricardo Canese v. Paraguay. Merits, reparations and costs. Judgment of August 31, 2004. Series C No. 111, para. 175, and Case of García Asto and Ramírez Rojas v. Peru. Preliminary objection, merits, reparations and costs. Judgment of November 25, 2005. Series C No. 137, para. 191, and Case of Mohamed v. Argentina, para. 131. 152 Cf. Case of Vélez Loor v. Panama. Preliminary objections, merits, reparations and costs. Judgment of November 23, 2010. Series C No. 218, para. 187. 153 Cf. Case of Vélez Loor v. Panama. Preliminary objections, merits, reparations and costs. Judgment of November 23, 2010. Series C No. 218, para. 183 (“in the interest of legal certainty, it is essential that the punitive norm, whether criminal or administrative, exists and is known or may be known, before the act or omission that violates it, and which it is intended to punish. The definition of an act as illegal, and the establishment of its legal effects must precede the conduct of the individual who is considered an offender. Otherwise, the individual would be unable to adapt his or her behavior in accordance with a valid and certain legal system that expresses the reproach of society and its consequences. These are the grounds for the principles of legality and of the nonretroactivity of an unfavorable punitive norm”). See also Case of Baena Ricardo et al. v. Panama. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 106; Case of Yvon Neptune v. Haiti. Merits, reparations and costs. Judgment of May 6, 2008. Series C No. 180, para. 125, and Case of García Asto and Ramírez Rojas v. Peru. Judgment of November 25, 2005. Series C No. 137, para. 191. 154 Regarding criminal offenses, in the Case of García Asto and Ramírez Rojas v. Peru, the ICourtHR established that “definitions of crimes must clearly describe the criminalized conduct, establishing its elements, and the factors that distinguish it from other forms of conduct that are either not punishable or punishable with noncriminal measures. The American Convention requires States to make every effort to apply criminal sanctions with strict respect for the basic rights of the individual, after carefully ascertaining the actual existence of illegal conduct. In this regard, it is incumbent on the criminal judge, when applying criminal law, to abide strictly by its provisions and to be extremely rigorous when relating the conduct of the accused to the definition of the offense, in order not to punish acts that are not punishable under the legal system”; Case of García Asto and Ramírez Rojas v. Peru. Judgment of November 25, 2005. Series C No. 137, paras. 188 to 190. See also Case of Fermín Ramírez v. Guatemala. Merits, reparations and costs. Judgment of June 20, 2005. Series C No. 126, para. 90; Case of Lori Berenson Mejía v. Peru. Merits, reparations and costs. Judgment of November 25, 2004. Series C No. 119, para. 125; Case of De la Cruz Flores v. Peru. Merits, reparations and costs. Judgment of November 18, 2004. Series C No. 115, paras. 79, 81 and 82, and Case of Baena Ricardo et al. v. Panama. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 106. 155 In this regard, the ICourtHR has indicated that “administrative sanctions are, like criminal sanctions, an expression of the State’s punitive power and, at times, they are similar to these in nature. They both entail 32