without the interference of the public authorities limiting or obstructing the exercise of the respective right.”281 As regards the collective dimension, the Court has ruled that in exercising this right, people “enjoy the right and freedom to seek the common achievement of a licit goal, without pressure or interference that could alter or change their purpose.”282 The Inter-American Court has also established that the positive obligations of preventing and investigating breaches of this right must be enforced “even in the sphere of relations between individuals, if necessary.”283 202. In its precedents, the Court has constantly ruled that “freedom of association can only be exercised in a situation in which fundamental human rights are fully guaranteed and respected, particularly those related to the life and safety of the individual.”284 Consequently, it has ruled that “an impairment of the right to life or to humane treatment attributable to the State may, in turn, give rise to a violation of Article 16.1 of the Convention when that violation arises from the victim’s legitimate exercise of the right to freedom of association.”285 203. The IACHR notes that as indicated in the established facts in the case at hand, Carlos Escaleras Mejía founded and led the Coordinating Committee of Peoples’ Organizations of Aguán (COPA), a community environmentalist organization with a great impact in the region. In addition, the Commission notes that from within that organization, in the weeks before his death, Mr. Escaleras denounced the construction of a processing plant that would have caused pollution along the Tocoa River. The Commission again points out that Mr. Escaleras’s visibility as an environmentalist leader was acknowledged by the State itself. 204. On this point, the Commission has stated that the activities to defend human rights bear a particularly close relationship to the legitimate exercise of the right to freedom of association. Therefore, “any act that tends to impede (...) or in any way impedes the purposes for which they have formally associated, is a direct attack on the defense of human rights.”286 The Court has also ruled that “States have the duty to provide the necessary means for human rights defenders to conduct their activities freely; […] to refrain from placing restrictions that would hinder the performance of their work, and to conduct serious and effective investigations of any violations against them, thus preventing impunity.”287 281 I/A Court H. R., Case of Huilca Tecse v. Peru, Merits, Reparations, and Costs, Judgment of March 3, 2005, Series C No. 121, para. 282 I/A Court H. R., Case of Huilca Tecse v. Peru, Merits, Reparations, and Costs, Judgment of March 3, 2005, Series C No. 121, para. 69. 69. 283 I/A Court H. R., Case of Kawas Fernández v. Honduras, Merits, Reparations, and Costs, Judgment of April 3, 2009, Series C No. 196, para. 144. Cf.: I/A Court H. R., Case of Huilca Tecse v. Peru, Merits, Reparations, and Costs, Judgment of March 3, 2005, Series C No. 121, para. 76; and I/A Court H. R., Case of Cantoral Huamaní and García Santa Cruz v. Peru, Preliminary Objection, Merits, Reparations, and Costs, Judgment of July 10, 2007, Series C No. 167, para. 141. 284 I/A Court H. R., Case of Kawas Fernández v. Honduras, Merits, Reparations, and Costs, Judgment of April 3, 2009, Series C No. 196, para. 150; Case of Huilca Tecse v. Peru, Merits, Reparations, and Costs, Judgment of March 3, 2005, Series C No. 121, para. 75; and Case of Cantoral Huamaní and García Santa Cruz v. Peru, Preliminary Objection, Merits, Reparations, and Costs, Judgment of July 10, 2007, Series C No. 167, para. 146. 285 I/A Court H. R., Case of Kawas Fernández v. Honduras, Merits, Reparations, and Costs, Judgment of April 3, 2009, Series C No. 196, para. 150. Cf.: I/A Court H. R., Case of Cantoral Huamaní and García Santa Cruz v. Peru, Preliminary Objection, Merits, Reparations, and Costs, Judgment of July 10, 2007, Series C No. 167, para. 147. 286 IACHR, Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II.124 doc. 5 rev. 1, March 7, 2006, para. 76; Report No. 31/96, Case 10.526, Merits, Arnoldo Juventino Cruz (Guatemala), October 16, 1996, para. 119; and Report No. 49/99, Case 11.610, Merits, Loren Laroye Riebe Star, Jorge Barón Guttlein, and Rodolfo Izal Elorz (Mexico), April 13, 1999. 287 I/A Court H. R., Case of Kawas Fernández v. Honduras, Merits, Reparations, and Costs, Judgment of April 3, 2009, Series C No. 196, para. 145; Case of Nogueira de Carvalho et al. v. Brazil, Preliminary Objections and Merits, Judgment of November 28, 2006, Series C No. 161, para. 77; and Case of Valle Jaramillo et al. v. Colombia, Merits, Reparations, and Costs, Judgment of November 27, 2008, Series C No. 192, para. 91. 39