95 Mosquera, as well as the continuing threats, harassment and assaults that have continued as of the present time against said defenders and their next of kin.466 The IACHR specifically expresses that it considers that all of these incidents “are part of a pattern of persecution and lack of protection being faced by these human rights defenders in the Comuna 13 area of Medellín, Colombia.”467 330. The Commission also considers proven in the matter that concerns us (paragraphs 160166 above) that the historical behavior of illegal armed groups, military operations implemented during 2002, and the gradual entrenchment of the paramilitary forces in Comuna 13 have had a disruptive effect on civic, social and grass-roots organizations working in defense of human rights in said locality. The national and international community – including the IACHR – has documented how members and leaders of these organizations – including the Community Action Boards and a variety of nongovernmental entities such as the AMI – have been the victims of forms of persecution, threats, arbitrary detentions, illegal searches, and targeted murders because they not played by the rules set by these groups.468 331. The State has promoted the repetition of these acts by failing to adopt reasonable measures of prevention, protection, and legitimization of their work as defenders in a known context of insecurity and armed conflict in Comuna 13. According to prior findings, the Commission reiterates the need for the Colombian State to urgently adopt measures in order to protect and encourage the work of women human rights defenders in the context of the armed conflict that has wracked the country. This gives rise to the obligation of the State to investigate and punish with full urgency and due diligence any violation of the right to free association as a guarantee of non-repetition, in an effort to put into place safe conditions for the work of human rights defenders. 332. By virtue of these considerations, the IACHR considers that the State has violated the right to free association of Ms. Rúa, Ospina, Naranjo, Mosquera, and Yarce, in breach of Article 16 of the American Convention, in connection with Article 1.1 of the same instrument. G. Right to a Fair Trial and Effective Judicial Protection (Articles 8.1469 and 25470), in connection with Article 1.1 of the American Convention, and Article 7 of the Convention of Belém do Pará471 466 Also see, for example, IACHR, Press Release, IACHR Condemns Continued Threats and Murders Directed against Human Rights Defenders and their Families in Colombia, March 7, 2011; see above paragraphs with description of information received by the Court during the time of effect of the provisional measures in the matter of Mery Naranjo et al and decisions issued therein. 467 IACHR, Press Release, IACHR Condemns Continued Threats and Murders Directed against Human Rights Defenders and their Families in Colombia, March 7, 2011. 468 IACHR, Press Release No. 15/03, IACHR Rapporteur Concludes Working Visit to the Republic of Colombia, June 27, 2003; Risk Report N˚ 009-07, Office of the Ombudsman of Colombia, pg. 1; Risk Report N˚ 016-10, Office of the Ombudsman of Colombia, pgs. 6 and 7; United Nations, Report of the United Nations High Commissioner for Human Rights on the Human Rights Situation in Colombia, 2002 Annual Report February 24, 2003, par. 46. 469 Article 8.1 of the American Convention provides as follows: Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature. 470 Article 25 of the American Convention establishes that:

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