November 2002 until her death, Mrs. Chinchilla Sandoval had to serve part of her sentence at the COF with a physical impairment; this implies that the State had a reinforced obligation to guarantee her right to health. In her particular case, it is clear that her vulnerability as a person deprived of liberty, subject to the power of the State, intersected with the vulnerability derived from her condition of disability. This caused, to her detriment, very different problems in relation to those deprived of liberty without disabilities and without adequate health care services. In other words, guaranteeing the right to health of a person with disabilities deprived of liberty involves specific and differentiated obligations, including reasonable accommodation, which must be applied to the particular case in order to guarantee the enjoyment of a specific right in equality of conditions. 6. I consider that the traditional analysis carried out by the Inter-American Court of Human Rights, in light of the right to life and personal integrity, is limited in this case, given that these two rights do not fully incorporate certain obligations associated specifically with the “right to health,” namely: accessibility, availability, quality and acceptability, or, the provision of reasonable accommodation to guarantee to persons with disabilities the enjoyment of their right to health. In understanding the relationship between the right to health and health care systems in prisons, it is essential to properly apply a rights-centered approach to these issues of special importance and sensitivity to the most disadvantaged groups in our region, including persons deprived of liberty and particularly those with some type of disability. 7. The Judgment recognizes that “health should be understood as a fundamental and indispensable guarantee for the exercise of the rights to life and personal integrity.”6 However, the Inter-American Court of Human Rights omits to expressly mention the “right to health,” linking both medical care and the health services directly to the effects on the right to life and personal integrity. The majority view considers that the effects are related to the protection of health (an expression used throughout the Judgment instead of the “right to health”). On this point, we should understand that the expression “protection of health” is one of the facets of the “right to health.”7 Furthermore, it should be recalled that regardless of the denomination given to the right to health, this literal interpretation does not annul its content. 8. For that reason I issue this separate opinion, considering the need to emphasize, analyze and explore some elements of this case in relation to the “right to health” of persons deprived of liberty, and particularly of those with disabilities, which are fundamental for the development of the Inter-American System of Human Rights and for the persons who have recourse to it in search of justice. Accordingly, I will address: I) Mrs. Chinchilla Sandoval’s that “the State’s duty to provide health services to persons in its custody is an obligation which derives […] from its duty to guarantee the rights to life and humane treatment of prisoners, and that this international responsibility is maintained even in the event that such services are provided in prisons by private contractors.” Cf. IACHR. Report on the Human Rights of Persons Deprived of Liberty in the Americas, Inter-American Commission of Human Rights, OEA/ Ser. L/V/II Doc. 64, December 31, 2011, paras. 21 and 22. Cf. Case of Chinchilla Sandoval v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of February 29, 2016, Series C No. 312, para. 177. 6 Committee on Economic, Social and Cultural Rights, General Comment 14, The Right to the Highest Attainable Standard of Health (Article 12 of the International Covenant on Economic, Social and Cultural Rights), (Twenty-second Session, 2000), U.N. Doc. E/C.12/2000/4 (2000), paras. 7-9. 7 3