16 36 and proportionate to the end sought. Distinctions based on grounds explicitly enumerated under pertinent articles of international human rights instruments are subject to a particularly strict level of scrutiny whereby states must show an especially weighty interest and compelling 37 justification for the distinction. 63. Thus, the IACHR has considered that a restriction must be based on very compelling reasons and that the burden of proof rests with the State. Hence, when a restriction is premised on a "suspect category," the Commission accepts the "reversal of the burden of proof" and the "presumption of invalidity.”38 In effect, the close scrutiny that must be done in the case of distinctions based on “suspect categories” serves to guarantee that the distinction is not based on the prejudices and/or stereotypes that generally surround suspect categories of distinction.39 In practical terms, this means that after presenting such a distinction, the burden of proof falls on the State, and the general criteria must be subject to close scrutiny wherein it is not enough for the State to argue the existence of a legitimate goal; instead, the goal sought through the distinction must represent a particularly important purpose or a pressing social need.40 Furthermore, it is not enough for the measure to be suitable or for a logical causal relationship to exist between it and the goal sought; instead, it must be strictly necessary to attain that goal, meaning that no other less harmful alternative exists.41 Finally, to meet the proportionality requirement, the existence of an appropriate balance of interests in terms of the level of sacrifice and the level of benefit, must be argued.42 36 See, inter alia, IACHR, Report No. 51/01, Case 9903, Ferrer-Mazorra et al. (United States), Annual Report of the Inter-American Commission on Human Rights 2000, OEA/Ser./L/V/II.111, doc. 20, rev., April 16, 2001, par. 238 37 See, inter alia, IACHR, Report on Terrorism and Human Rights, OEA/Ser.L/V/ll.116 Doc. 5 rev. 1 corr., October 22, 2002, paragraph 338, citing, inter alia, Repetto, Inés, Supreme Court of Justice (Argentina), November 8, 1988, Judges Petracchi and Bacqué, par. 6; Loving v. Virginia, 388 US 1, 87 (1967); Eur. Court H.R., Abdulaziz v. United Kingdom, Judgment of 28 May 1985, Ser. A No. 94, par. 79. 38 See, inter alia, IACHR, Access to justice for women victims of violence in the Americas, OEA/Ser.L/V/II., Doc. 68, January 20, 2007, par. 58; IACHR, The Situation of Persons of African Descent in the Americas, OEA/Ser.L/V/II., Doc. 62, December 5, 2011, par. 91. 39 IACHR, Application before the Inter-American Court of Human Rights, Case of Karen Atala and Daughters v. Chile, September 17, 2010, par. 88. 40 See, inter alia, IACHR, Access to Justice for Women Victims of Violence in the Americas, OEA/Ser. L/V/II. doc.68, January 20, 2007, paragraphs 80, 83; Report on Terrorism and Human Rights, OEA/Ser.L/V/ll.116 Doc. 5 rev. 1 corr., October 22, 2002, par. 338; Report No. 4/01, María Eugenia Morales de Sierra (Guatemala), January 19, 2001, par. 36; Annual Report 1999, Considerations regarding the compatibility of affirmative action measures designed to promote the political participation of women with the principles of equality and non-discrimination, Chapter VI; ECHR, Salgueiro da Silva Mouta v. Portugal, Application No. 33290/96, December 21, 1999, par. 29; Belgian Linguistics (Merits), Judgment of 23 July 1968, p. 34; LustigPrean and Beckett v. United Kingdom, Applications Nos. 31417/96 and 32377/96, 27 September 1999, par. 80; Smith v. Grady v. United Kingdom, Applications Nos. 33985/96 and 33986/96, 27 September 1999, par. 87. 41 See, inter alia, IACHR, Report No. 38/96, X and Y (Argentina), October 15, 1996, par. 74; Access to Justice for Women Victims of Violence in the Americas, OEA/Ser. L/V/II. doc.68, January 20, 2007, par. 83; ECHR, Karner v. Austria, Application No. 40016/98, 24 July 2003, par. 41; Salgueiro da Silva Mouta v. Portugal, Application No. 33290/96, December 21, 1999, par. 29; Belgian Linguistics (Merits), Judgment of July 23, 1968, p. 34. 42 IACHR, Application before the Inter-American Court of Human Rights, Case of Karen Atala and Daughters v. Chile, 17 September 2010, par. 89.