efforts made by the state after the above were repealed; (iii) the criminal investigation of the crimes committed to the detriment of Victoria Grisonas and Mario Julien; (iv) the search for their remains; (v) the investigation into the crimes committed to the detriment of the Larrabeiti Yáñez siblings; and (vi) the reasonable delay in conducting the criminal investigations. 161. As indicated in the section on the determination of the facts, on December 24, 1986, Law No. 23.492, called “Full Stop,” was passed and, on June 8, 1987, Law No. 23.521, called “Due Obedience,” was passed. Along with the pardons decreed by President Carlos Menem (No. 1002/98 et al.), these laws led to a large number of criminal cases, which were filed after the restoration of democracy to investigate incidents committed during the dictatorship, came to a standstill. These laws were then repealed by Law 25.779 and afterwards declared unconstitutional by the CSJN on June 14, 2005. 162. Therefore, for more than 18 years, the “Full Stop” and “Due Diligence” laws were in force and led to a situation of total impunity regarding the crimes against humanity perpetrated against the Julien-Grisonas family, which, according to the inter-American system’s consistent case law, are not eligible to benefit from amnesty because they involve grave human rights violations. During this long period of time, any attempt by the Larrabeiti Yáñez siblings to seek justice was thwarted. Therefore, by adopting, implementing, and enforcing the laws called “Full Stop” and “Due Obedience,” both of which exerted a direct impact on the possible clarification of the facts, the state violated Articles 8.1 and 25 of the Convention, in connection with its Articles 1.1 and 2 and with Article I, subparagraph b), of the IACFDP, to the detriment of the Larrabeiti siblings and their biological mother and father. 163. The Inter-American Commission recognizes the importance of the judgment of unconstitutionality issued on June 14, 2005 by the CSJN in the case of “Simón, Julio Héctor.” It also recognizes and stresses the efforts made by the state of Argentina in terms of public policies for memory, truth, and justice after the repeal of Laws Nos. 23.492 and 23.521, and in particular the numerous criminal cases filed for grave human rights violations promoted since then. With this turnabout, Argentina once again became a historical milestone as a result of the Trial of the Juntas in 1985, a trial that is the cornerstone for Argentina’s transition to democracy and that is also especially important internationally for being the first country in the world to bring its senior military commanders to trial for human rights violations after the restoration of democracy. The Commission stresses that Argentina has been recognized globally as a model regarding memory, truth, and justice. 164. Nevertheless, despite these major efforts, in the instant case, the Commission must examine, on the basis of available information, whether or not the grave human rights violations, which in addition were crimes against humanity according to the terms indicated in the context and recognized by the state of Argentina, perpetrated against the Julien-Grisonas family, were adequately investigated and punished, in line with the state’s international obligations as already summed up in the present report. 165. According to proven facts, on May 31, 2011, Federal Criminal Oral Court No. 1, in the framework of the case known as “Orletti I,” convicted four former agents of the SIDE and sentenced them to life imprisonment and to 25 and 20 years of prison, for various crimes committed in “Orletti,” among which the unlawful deprivation of liberty and torture of Victoria Grisonas. This judgment confirmed her unlawful deprivation of liberty in this secret detention center, as well as the suffering of torture and inhuman detention conditions. The judgment was upheld on appeal on October 7, 2013. 166. The Commission stresses that, on the basis of the above-mentioned judgment of conviction, the state conducted an effective and diligent investigation in accordance with the inter-American standards previously cited. In particular, said judgment reflected a comprehensive vision of the facts, because it took into account the background and context in which they occurred, revealing structures of participation. Nevertheless, the IACHR observes that, although long prison sentences were given, proportional to the gravity of the crimes, the codified crime of forced disappearance was not applied. This was incorporated into Article 142ter of the Criminal Code by means of Law 26.679 enacted on May 5, 2011. As set forth in the previously cited interAmerican case, in cases of forced disappearance, it is this codified criminal category that must be applied. Therefore, the Commission concludes that, because Argentina had not codified the crime of forced

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