40 reproductive autonomy.” It indicated that an international consensus existed that non-consensual sterilization constituted a form of violence against women in which a series of human rights are infringed. The Commission added that, in the area of maternal health, it “has considered that the States have a duty to adopt affirmative measures to guarantee the accessibility of maternal health services and their availability, acceptability and quality as part of their obligations deriving from the principles of equality and non-discrimination.” 136. The Commission recalled that it “has recognized that certain groups of women, as in the case of I.V., an immigrant woman of modest means, suffer discrimination throughout their lives based on one or more factors in addition to their sex, which increases their exposure to acts of violence and other violations of their human rights.” The Commission considered that “this case is an example of the multiple forms of discrimination that intersect to hinder the enjoyment and exercise of human rights by certain groups of women on the basis of their sex, immigrant status, and economic situation.” In this regard it argued that “women migrants of scarce resources are in a special situation of vulnerability, often being forced to seek public medical services that may not be suitable to meet their needs due to the limited nature of the care options available to them.” 137. The Commission also argued that there were signs that the medical team that performed the surgery on I.V. was influenced by gender stereotypes concerning the inability of women to make autonomous decisions with regard to their own reproduction. In this regard, it considered that the medical decision to perform sterilization without I.V.’s informed consent reflected a notion that medical personnel are empowered to take better decisions than the woman concerned regarding control over her reproduction. According to the Commission, “the presence of these kinds of gender stereotypes in health personnel has a differentiated impact on women and leads to discrimination against them in the health services and especially in the provision of sexual and reproductive health care services.” In this regard, the Commission recalled that persistent gender stereotypes in the health sector act as an obstacle to women’s access to maternal health services, which also amounts to discrimination in women’s access to health. 138. The Commission concluded that the absence of informed consent led to I.V. not receiving the appropriate maternal health services in relation to her reproductive capacity, thereby curtailing her free and autonomous choice in this sphere unique to women. Consequently, the Commission argued that I.V.’s non-consensual sterilization constituted a form of discrimination against her in relation to the guarantee of her right to personal integrity under Article 5(1) of the American Convention, as well as her right to private and family life and to raise a family under Articles 11 and 17 of the American Convention. 139. The representative indicated that discrimination existed in cases of forced sterilization not only in relation to Articles 5(1), 11(2) and 17(2) of the American Convention, but also in relation to Article 13(1) of this instrument. In this regard, she argued that the right to receive information (Article 13 of the American Convention) was violated based on discrimination and, also, expanded on the factors of discrimination that presumably motivated the violation of I.V.’s rights. In particular, she argued that “enforced sterilization is a discriminatory phenomenon that affects women just as, in this case, it affected I.V. because she is a woman.” She also argued that I.V. was attended in the Women’s Hospital with the profile of being a poor woman with little schooling, of another national origin, and, according to the representative, this had given rise to feelings and attitudes of xenophobia and discrimination. Lastly, she indicated that, in addition to being a “woman,” “poor” and “Peruvian,” I.V. was and is a refugee in Bolivia and, as such, had also been a victim of discrimination. In sum, she concluded that I.V. suffered numerous types of discrimination in the Women’s Hospital. 140. The State argued that it had “never exercised gender-based discrimination in relation to I.V.’s reproductive rights,” and noted that “there is no evidence whatsoever proving that I.V. was subjected to discriminatory treatment de iure or de facto by the State in relation to the rights recognized in