of accessibility and reasonable accommodation— constitutes a violation of the rights of persons with disabilities under the social model. 18. For example, in relation to the first phase of the ECHR’s jurisprudence, in the case Farbtuhs v. Latvia, of 2004, the Court considered that a person with a category 1 disability, with various impairments, which prevented him from moving around the prison independently, constituted a violation of Article 3 of the European Convention because the petitioner’s continued detention was not appropriate given his age, his ailments and his health. Regarding the monitoring and daily care due to the petitioner, the Court considered, in the first place, that although he received family visits for prolonged periods of 24 hours and regularly exercised this right, the visit was not daily. In second place, it was also proven that although the victim was supervised and assisted by medical staff during the infirmary’s working hours, outside of those hours assistance was provided by fellow inmates, acting as volunteers or as part of the prison service.15 In this situation, and in this case, the ECHR concluded that it was unlikely that such a solution was adequate as, for at least part of the time, it left most of the responsibility [for helping a disabled person] to unqualified prisoners; although the victim did not report any incident or specific disadvantage of this form of assistance and only mentioned that on some occasions the inmates had refused, the fact is that this was not sufficient to counteract the anxiety and distress felt by an infirm person, conscious that he would not receive any qualified help in the event of an emergency.16 19. Regarding the second moment—the transition phase — in the ECHR’s case law, the autonomy of persons with disabilities originated with the case Vincent v. France of 2006, where the court considered that to detain a disabled person in a prison where he could not move about and, in particular, could not leave his cell independently, amounted to degrading treatment.17 In this case the European Court ruled that the violation arose from the failure to ensure that the person could leave his cell independently, and move around within the prison; however, it makes no reference to the failure to adopt measures of accessibility or, in his case, any reasonable accommodation that might have been necessary. It should also be emphasized that this case concerns a person with a physical limitation consisting of paraplegia, where the individual retained mobility in his upper body in a normal and autonomous manner.18 20. Finally, and in third place, the development of the ECHR’s case law on independence occurs within the framework of the social model of disability. In this regard, in the case of Grimailovs v. Latvia, of 2013, the victim had become a paraplegic and, after considering the physical conditions of his detention, and the failure to adapt the facilities to allow for the movement of a person in wheelchair,19 the European Court found that: In the light of the 15 Cf. ECHR, Case of Farbtuhs v. Latvia, No. 4672/02, of December 2, 2004, paras. 11, 39, 40, 41 and 45. 16 Cf. ECHR, Case of Farbtuhs v. Latvia, No. 4672/02, of December 2, 2004, para. 60 17 Cf. ECHR, Case of Vincent v. France, No. 6253/03, Judgment of October 24, 2006, para. 113. 18 Cf. ECHR, Case of Vincent v. France, No. 6253/03, Judgment of October 24, 2006, para. 9. 19 Cf. ECHR, Case of Grimailovs v. Latvia, No. 6087/03, Judgment of September 25, 2013, paras.70, 157 and 158. 7