However, although persons with some limitation have special protection, this “special protection” must not be confused with an “assistentialist” view of persons with disabilities.13 15. It should be emphasized that the Inter-American Court concluded that given the situations suffered by Mrs. Chinchilla at the COF, “[…] it was reasonable that the State should adapt, at least minimally, the prison facilities to her condition of disability [through the adoption of measures of accessibility and reasonable accommodation]” or, otherwise “have staff available to assist Mrs. Chinchilla and to mobilize her.”14 This assertion could convey the idea that the Inter-American Court adopts the option of the previous model — the clinical model— over the social model of disability. However, from my perspective, I consider it necessary to clarify this point. 16. In the first place, the conclusion reached by the Inter-American Court in the instant case should not be interpreted in the sense of excluding one option for another, that is, exempting the State from its obligation to create an accessible environment for persons with disabilities and to adopt measures of reasonable accommodation for the specific case (and future cases), by simply providing assistance to the disabled person. On the contrary, the above conclusion must be interpreted to mean that both measures, according to the specific case, complement each other; that is, in some situations it will be necessary - even within the human rights model for persons with disabilities - to provide assistance that complements the measures of accessibility and reasonable accommodation, as long as this assistance does not compromise the independence and autonomy of the disabled person to whom it is provided. In second place, international law does not prohibit, in some cases, the provision of assistance by third parties, without this breaching the principle of independence. The foregoing has been consistent with the social model of disability espoused at the international level. 17. The European Court of Human Rights has conceived the principle of independence from the standpoint of three “jurisprudential moments” or phases regarding the assistance provided to persons with disabilities. In the first phase, prior to the adoption of the CRPD in 2007, from the perspective of the clinical model, the Strasbourg Court considered that when a person with some form of impairment was deprived of liberty, it was essential to provide assistance within the detention center. In the second phase, there was a period of transition in case law, which referred to the independence of disabled persons but without mentioning the adoption of measures of accessibility and reasonable accommodation within prisons. And, thirdly, after reinforcing the social model of disability in 2007 with the CRPD, the ECHR modified its concept and conceded that failure to provide assistance—and well as measures ensure full, equal and unrestricted access for all potential consumers, including persons with disabilities, in a way that takes full account of their inherent dignity and diversity. Universal design should contribute to the creation of an unrestricted chain of movement for an individual from one space to another, including movement inside particular spaces, with no barriers. Although ideally, universal design should be applied to a building from the outset, thereby helping to make its construction much less costly, the cost of subsequent adaptations to remove barriers cannot be used as an excuse for avoiding the obligation to gradually eliminate the obstacles to accessibility. Clearly, the elimination of barriers to accessibility for persons with disabilities also applies to prisons, so as to allow them to move around within the facility. Convention on the Rights of Persons with Disabilities, Article 2 and Cf. Committee on the Rights of Persons with Disabilities, General Comment No. 2, Article 9: Accessibility, CRPD/C/GC/2, May 22, 2014, para. 15. Cf. Committee on the Rights of Persons with Disabilities, Communication Nº 2/2010, Liliane Gröninger v. Germany, CRPD/C/D/2/2010, of July 7, 2014, para. 6.2. 13 Case of Chinchilla Sandoval v. Guatemala. Preliminary objection, Merits, reparations and costs. Judgment of February 29, 2016, Series C No. 312, para. 218. 14 6