REPORT No. 141/19
CASE 13.080
REPORT ON MERITS
BRISA LILIANA DE ANGULO LOZADA
BOLIVIA
September 28, 2019

I.

INTRODUCTION

1. On January 20, 2012, the Inter-American Commission on Human Rights (hereinafter "the Inter-American
Commission," "the Commission," or "the IACHR") received a petition presented by the Child and Family
Advocacy Clinic of Rutgers University, the International Human Rights Law Clinic of American University, the
Oficina Jurídica para la Mujer, and Maria Leonor Oviedo Bellott (hereinafter "the petitioner")1 alleging that the
Plurinational State of Bolivia (hereinafter "the Bolivian State," "the State," or "Bolivia") was internationally
responsible to the detriment of Brisa Liliana De Angulo Losada (hereinafter "the alleged victim") due to its
failure to protect her, investigate, and punish the sexual violence she suffered as a child.
2. The Commission approved the admissibility report number 25/17 on March 18, 2017.2 On April 7, 2017,
the Commission notified the parties of the report and gave them the time provided for in the Rules of Procedure
to submit additional comments on the merits. The Commission made itself available to the parties to help them
reach a friendly settlement, but the conditions were not met for launching that process. Both parties submitted
comments on the merits, and all the information received was duly transferred between the parties.
II. POSITIONS OF THE PARTIES
A. Petitioner:
3. The petitioner alleges that Brisa Liliana De Angulo was the victim of sexual violence as an adolescent and
was later re-victimized by the State when she sought redress and protection, which violated her human rights
by (i) not protecting her from the cruel and inhuman sexual violence she suffered as an adolescent, causing
harm to her dignity; (ii) maintaining a justice system that treated her cruelly, inhumanly, and without regard
for her dignity, while failing to investigate, try, or punish her rapist; and (iii) discriminating against her as an
adolescent and a woman.
4. Regarding the facts, the petitioner states that Brisa is a U.S. and Colombian citizen who was living with her
family in the city of Cochabamba, Bolivia. It states that between September 2001 and May 2002, when she was
16 years old, she was sexually assaulted and raped repeatedly by her cousin, Eduardo Gutiérrez Angulo, a
Colombian citizen, who is 10 years older than she is. She said she was also abused and beaten by her attacker,
which she originally hid from her family because she was afraid of his threats. The petitioner states that in May
2002, on noticing Brisa’s dramatic physical and psychological decline, her parents took her on a trip to the
United States, and there they learned about what had happened. After the girl tried to commit suicide, her
parents returned with her to Bolivia to report the crime to State authorities.
5. From that moment on, the alleged victim claims having experienced a process of revictimization at the
hands of the police, prosecutors, judges, medical and judicial staff, which she described as skepticism,
insensitivity, and abuse. Specifically, the petitioner alleges that Brisa was subjected to two cruel physical
examinations, with those in charge of conducting a forensic examination being all men, who acted without any
On May 8, 2015, the IACHR received a communication from Brisa De Angulo informing it that the International Human Rights Law Clinic
of American University would no longer be representing her. The communication added that Hughes Hubbard & Reed LLP and Equality
Now would join the petitioners in this case.
2 IACHR. IACHR. 25/17. Petition 86-12. Admissibility. Brisa Liliana De Angulo Losada. Bolivia. March 18, 2017. The petition was found
admissible in relation to Articles 5, 8, 11, 19, 24, and 25 of the American Convention, in conjunction with the obligations established in
Articles 1(1) and 2 of the Convention, as well as Article 7 of the Convention of Belém do Pará.
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