application of the special remedy for reversal; and (3) that the remedy lodged by Mr. Spoltore was inappropriate for establishing abridgments of constitutional guarantees.18 38. Finally, the parties agreed on the contention that on September 16, 1997, Mr. Spoltore lodged, with the office of the Inspector General of the Buenos Aires Supreme Court, a disciplinary complaint alleging delays and negligence in the Labor Tribunal’s processing of his case. That complaint was resolved almost two years later, on April 16, 1999. The decision found that although there had been a delay, the appropriate course of action was a reprimand for the clerk of the court involved for the delay in referring the proceedings to expert advice and for the delay in preparing and signing the deeds of notification. V. ANALYSIS OF LAW 39. In its admissibility report, the Commission said that at the merits phase it would rule on the alleged violation of the right to a decision within a reasonable time and on the alleged denial of justice in the occupational sickness suit lodged by Mr. Spoltore against the company Cacique Camping S.A. and heard by the Labor Tribunal. The purpose of this report is not to establish whether or not Mr. Spoltore was entitled to the compensation he sought, nor to question the result of the labor proceedings. In the circumstances of the case at hand, such a ruling would exceed the Commission’s competence. Consequently, the analysis offered below is intended to determine whether the Argentine State, through its judicial authorities that participated in this case, provided Mr. Spoltore with an effective and grounded remedy in accordance with the guarantees of due process and, particularly, with the guarantee of prompt recourse on which the petitioner centered his claims. A. Right to a fair trial19 and right to judicial protection20 1. General considerations 40. The right to a fair trial covers all the procedural requirements that must be observed at trial so that persons can defend their rights adequately against actions by the State. 21 Both the Commission and the Inter-American Court of Human Rights (hereinafter “the Court,” or “the Inter-American Court”) have repeatedly stated that, in general, the guarantees established in Article 8 of the American Convention are not restricted to criminal proceedings but instead apply to trials of other kinds. 22 Specifically, in proceedings involving people’s rights or interests, the “due guarantees” enshrined in Article 8.1 of the American Convention are applicable, 23 including the provision establishing the right to a decision within a reasonable time. That reasonable time must be seen in light of the total duration of the proceedings, from the first stage in the process up to the adoption of the final judgment.24 18 Annex 4. Motion to vacate filed by Mr. Spoltore with the Supreme Court of Justice, dated April 29, 1996. Annex to Mr. Spoltore’s petition of September 5, 2000. Annex 2. Appeals ruling of the Supreme Court of Justice of the Province of Buenos Aires, dated August 16, 2000. Annex to Mr. Spoltore’s petition of September 5, 2000. 19 Article 8 of the American Convention establishes, in its pertinent parts, that: “1. 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.” 20 Article 25.1 of the American Convention provides that: “Everyone has the right to simple and prompt recourse, or any other effective recourse, to a competent court or tribunal for protection against acts that violate his fundamental rights recognized by the constitution or laws of the state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties.” 21 IACHR. Report No. 42/14. Case 12.453. Merits. Olga Yolanda Maldonado Ordóñez. Guatemala. July 17, 2014, para. 62, citing: I/A Court H. R. Case of Genie Lacayo v. Nicaragua. Judgment of January 29, 1997. Series C No. 30, para. 74; I/A Court H. R. Case of Claude Reyes et al. v. Chile. Judgment of September 19, 2006. Series C No. 151, para. 116; and I/A Court H. R. Judicial Guarantees in States of Emergency (Arts. 27.2, 25, and 8 of the American Convention on Human Rights). Advisory Opinion OC-9/87 of October 6, 1987. Series A. No. 9, para. 27. 22 IACHR. Report No. 65/11. Case 12.600. Merits. Hugo Quintana Coello and Others (Justices of the Supreme Court). Ecuador. March 31, 2011, para. 102. 23 I/A Court H. R. Case of Barbani Duarte et al. v. Uruguay. Merits, Reparations, and Costs. Judgment of October 13, 2011. Series C No. 234, para. 118; and Case of Claude Reyes et al. v. Chile. Merits, Reparations, and Costs. Judgment of September 19, 2006. Series C No. 151, para. 118. 24 I/A Court H. R. Case of Andrade Salmón v. Bolivia. Merits, Reparations, and Costs. Judgment of December 1, 2016. Series C No. 330, para. 200. 6