(2) The Court has merely ratified its consistent case law 7. Since the cases of the Constitutional Court v. Peru and Baena Ricardo et al. v. Panama, both in 2001, and up until the case of Vélez Loor v. Panama in 2010, ranging through cases such as Ivcher Bronstein v. Peru (2001), Yatama v. Nicaragua (2005), Sawhoyamaxa Indigenous Community v. Paraguay (2006), Claude Reyes et al. v. Chile (2006), Apitz Barbera et al. v. Venezuela (2008), and Escher et al. v. Brazil (2009), the Inter-American Court has reiterated that the Public Administration, in its different manifestations and dimensions, “is not excluded from complying with [the] obligation” to provide the interested party with “all the minimum guarantees that permit reaching just decisions.” “The minimum guarantees must be respected in administrative proceedings and in any other proceeding in which the decision may affect the rights of the individual.”2 8. In this regard, in the case of Baena Ricardo, the Inter-American Court considered that “[a]lthough Article 8 of the American Convention is entitled ‘Right to a Fair Trial [Note: in Spanish: ‘Garantias Judiciales], its application is not limited strictly to judicial remedies, ‘but [to the] whole series of requirements that must be observed in the procedural bodies’ to ensure that the individual is able to defend his rights adequately in any type of act of the State that could affect them. In other words, any act or omission of the State bodies within a proceeding, whether it be administrative, disciplinary or jurisdictional, must respect due process of law.”3 9. Similarly, in the case of Yatama with regard to Nicaragua, the Court indicated that “[a]ll the bodies that exercise functions of a jurisdictional nature have the obligation to adopt just decisions based on full respect for the guarantees of due process established in Article 8 of the American Convention.” In this regard, it interpreted Article 8(1) broadly, establishing that this article refers “to the right of everyone to be heard by a ‘competent judge or court’ ‘for the ‘determination of his rights.’” In addition, the Court clarified that this expression refers to any “public authority,” whether administrative, legislative or judicial, which, by its decisions, “may affect the determination of [the] rights” of the individual.4 10. On this basis, the application of Article 8(1) to decisions that determine rights and obligations of the individual in the administrative sphere is a fait accompli in the current status of the Court’s case law, and Article 29(b) of the Pact prohibits a regressive interpretation. 11. It would be more interesting to discuss whether, based on the interpretation already made by the Court, Article 8(1) of the Convention would be applicable to the decisions issued by a Council of Elders or the equivalent authority in an indigenous community, taking into account that the latter’s source of law, although it would not be the State, is, to a certain extent, sovereign, and its authority is recognized by some States Parties to the Convention for its members, provided that those decisions do not run counter to the norms of the State. 2 Case of Baena Ricardo et al. v. Panama. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 127. 3 Case of Baena Ricardo et al., supra nota 2, para. 124. 4 Case of Yatama v. Nicaragua. Preliminary objections, merits, reparations and costs. Judgment of June 23, 2005. Series C No. 127, para. 149. 2