proved that there was any justification for the inaction of the judicial authorities, the long periods of time during which nothing was done, the prolonged delay in the criminal proceedings, and the delay arising from the conflicts of competence. Consequently, the Court considers that the judicial authorities did not employ due diligence to reach a decision in the criminal proceedings. 368. Taking into account: (i) that in this case the integrity of the Hacienda Brasil Verde workers was in danger; (ii) the consequent urgency as a result of their situation of working in conditions similar to slavery, and (iii) the importance of deciding the proceedings in order to make reparation to the workers, as well as to halt the situation of slavery that existed in the haciendas, the Court considers that the State had a special obligation to act with due diligence and that it failed to comply with this obligation. Consequently, the Court concludes that the State violated the judicial guarantee of due diligence established in Article 8(1) of the American Convention on Human Rights, in relation to Article 1(1) of this instrument, to the detriment of the 43 Hacienda Brasil Verde workers who were found during the inspection of April 23, 1997, and who have been identified by the Court in this judgment (supra para. 199). B.2. Reasonable time 369. With regard to the promptness of the proceedings, the Court has indicated that the “reasonable time” referred to in Article 8(1) of the Convention must be assessed in relation to the total duration of the proceedings until a final judgment is handed down. 483 The right of access to justice implies that a dispute must be decided within a reasonable time, 484 because a prolonged delay may, of itself, constitute a violation of the judicial guarantees.485 370. Regarding the presumed failure to comply with the judicial guarantee of reasonable time in the criminal proceedings, the Court will examine the four criteria it has established in its case law in this regard: (i) the complexity of the matter; (ii) the procedural activity of the interested party; (iii) the conduct of the judicial authorities, and (iv) the effects generated on the legal situation of the person involved in the proceedings. 486 The Court recalls that it corresponds to the State to justify, based on these criteria, why it has required the time that has elapsed in order to hear the case and, if it fails to do so, the Court has broad powers to reach its own conclusions in this regard.487 371. In this case, the criminal proceedings relating to the April 1997 inspection began with the complaint filed by the Federal Public Prosecution Service in June that year and concluded with the declaration of prescription in 2008 (supra para. 157); thus, the proceedings lasted approximately 11 years. Consequently, the Court will now determine whether the time that passed was reasonable based on the criteria established in its case law. i) Complexity of the matter Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C No. 35, para. 71, and Case of Quispialaya Vilcapoma, para. 176. 483 484 Cf. Case of Suárez Rosero v. Ecuador. Merits, para. 71, and Quispialaya Vilcapoma, para. 176. Cf. Case of Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago. Merits, reparations and costs. Judgment of June 21, 2002. Series C No. 94, para. 145, and Case of Tenorio Roca, para. 237. 485 Cf. Case of Valle Jaramillo et al. v. Colombia. Merits, reparations and costs. Judgment of November 27, 2008. Series C No. 192, para. 155, and Case of Tenorio Roca, para. 238. 486 Cf. Case of Anzualdo Castro v. Peru. Preliminary objection, merits, reparations and costs. Judgment of September 22, 2009. Series C No. 202, para. 156, and Case of Quispialaya Vilcapoma, para. 178. 487 93

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