22 the Court declare the State responsible for the violation of the right to humane treatment of “the next of kin” of Jesús María Valle Jaramillo and Nelly Valle Jaramillo. 66. According to the Commission and the representatives, “the execution of Jesús María Valle did not occur in a void and was not an isolated case; rather it took place in a specific context as part of a series of murders, harassment, stigmatization, and attacks against individuals and social organizations dedicated to the defense of human rights. The consequences have continued over time owing to the ineffectiveness of the administration of justice in cases such as this.” To support these allegations, the Commission indicated, inter alia, that “[t]he State authorities themselves declared that the grave situation of vulnerability in which Colombian human rights defenders found themselves generated a increased responsibility of protection for the State […]. In this case, it was reasonable to think that the risk borne by Jesús María Valle Jaramillo merited that the State adopt measures in accordance with this increased responsibility of protection.” The Commission also indicated that “the authorities were aware of the risk and adopted measures to deal with it. However, those measures were insufficient […].” 67. In addition, the representatives argued that, “at the time the human rights defender Jesús María Valle Jaramillo was executed, the defense of human rights in Colombia took place in a context of systematic persecution and the absence of measures of protection and guarantees for the full and free exercise of this task, together with a pattern of impunity that […] still characterizes the investigations undertaken in response to acts of intimidation and violence […] against human rights defenders in different parts of the country.” Furthermore, the representatives indicated that between July 1, 1996, and December 31, 1998, “several human rights defenders were executed in similar circumstances, using a specific modus operandi.” 68. The representatives also insisted that Valle Jaramillo’s “permanent denunciation of joint actions by members of paramilitary groups and soldiers [placed him] in great danger. Despite this, his life was not protected in any way and, to the contrary, he was the passive subject of criminal complaints filed by the Commander of the Fourth Brigade of the National Army, which, [according to the representatives,] was one more reason for the attempt on his life.” The representatives alleged that, “[t]he criminal complaint filed by […] State agents against Jesús María Valle Jaramillo, seeking to discredit and intimidate [him], and to prevent his denunciations in defense of the population of Ituango, together with public defamation by the Governor of Antioquia at the time, jeopardized the human rights defender’s life. These acts of harassment and defamation potentially encouraged the paramilitary groups and those directly involved in the reported facts to take action against the humanist.” 69. Furthermore, the Commission and the representatives indicated that the illegal and arbitrary detention of Jesús María Valle Jaramillo, Nelly Valle Jaramillo, and Carlos Jaramillo Correa placed them in a situation of vulnerability resulting in the real and imminent danger that their other rights would be violated. According to the representatives, the situation of “absolute defenselessness […] must have caused them immense anguish, since the outcome was predictable; acts that corresponded to cruel, inhuman, and degrading treatment.” In addition, the Commission and the representatives alleged that “the execution of [Jesús María] Valle Jaramillo had a specific and grave impact on the stability of the family, which was deprived of the person who guided and supported it,” “because the pain and suffering caused by both his death and the circumstances surrounding the case constitute a violation of the physical and moral integrity of all [his] family.” 70. The State acknowledged that “Jesús María Valle Jaramillo was a well-known human

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