because when asleep their alertness and ability to defend themselves are substantially reduced. 38 24. The vulnerability of individuals and families to violations during nighttime house raids is exacerbated when women and children are present in the home, an issue we will examine in the following section. c. The special impact of the violation of the rights to privacy, intimacy and family life on vulnerable groups 25. The judgment recognizes that the negative effects of house raids are especially prejudicial for vulnerable groups, such as women and children. 39 The duty of due diligence and of enhanced protection in relation to the rights of members of vulnerable groups is widely recognized in this Court’s case law. 40 However, we believe it necessary to include some specific considerations on the differentiated impact on vulnerable groups, as occurred in this case. 26. Regarding women, one of the factors that reveal this vulnerability is the greater risk of violence, including sexual violence. As the Court has repeatedly asserted, the American Convention and the Convention of Belém do Pará 41 oblige States to adopt measures to prevent gender-based violence and to act with due diligence to investigate and punish those responsible, as well as to redress any violations that occur. 42 In the case of house raids – as explained above (see II.a), these are already permeated by a high level of intrusion and risk – States have the obligation to adopt reinforced measures to prevent the violation of women’s rights. In this regard, it is worth mentioning the position expressed by expert witness Guzmán Rodríguez: In the context of raids, arrests and deprivations of liberty, the gender approach should be implemented by a comprehensive range of measures that should include, at least, the following: (i) prior identification of those potentially affected by the said measures in order to plan the corresponding actions; (ii) prevention of the risk of gender-based violence, for example, by the prior training of those who take part in criminal procedures and the adoption of specific verification measures during such procedures; (iii) early identification of possible cases of gender-based violence (GBV); (iv) elimination of risk factors that could result in GBV; (v) investigation of all the facts that could constitute some form of GBV, and (vi) attention to and reparation for the victims of GBV. 43 27. It is also possible to note the presence of gender stereotyping during the house raids and this had a negative impact on the conduct of the state authorities. As the Court has recognized in, among others, the case of González et al. (“Cotton Field”) v. Mexico (2009), the subordination of women to practices based on gender stereotypes is exacerbated when it is reflected in the thinking and language of police authorities. 44 In the instant case, it is conspicuous that the women victims indicated on several occasions that they were subjected to extremely misogynistic and discriminatory language by the state For example, “At the same time, the reason for limiting nighttime searches — preventing abrupt intrusions on sleeping residents in the dark.” US Court of Appeals for the First Circuit. United States v. Young, 877 F.2d 1099, 1104 (1st Cir.1989) (BREYER, J.). 38 39 Cf. Judgment, para. 153. 40 For example: Case of Ximenes Lopes v. Brazil. Judgment of July 4, 2006. Series C No. 149, para. 103. Likewise, the United Nations Convention on the Elimination of All Forms of Discrimination Against Women (1979), ratified by Bolivia in 1990. 41 42 Case of González et al. (“Cotton Field”) v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of November 16, 2009. Series C No. 205, para. 258 43 Expert opinion provided by affidavit by Diana Guzmán on June 16, 2022 (evidence file, folio 12765). 44 Cf. Case of González et al. (“Cotton Field”) v. Mexico. supra, para. 401. 6