63 “only personal and effective sureties and the surety for the costs of a lawsuit were established as alternative measures to the deprivation of freedom during the proceeding.” Mr. Canese provided sufficient guarantees that he would abide by the punitive measure imposed, by providing material surety and by his preceding acts; c) The measure is also disproportionate, because it was imposed for more than eight years, when the possible sanction applicable was less than one year’s imprisonment; in this respect, it exceeded the time established as reasonable; d) The State did not prove the essential nature, proportionality and necessity of the measures restricting the freedom of movement imposed on the alleged victim; e) Rather than a precautionary measure, the restriction of Mr. Canese’s freedom of movement became an “anticipated sanction,” not established in the Paraguayan Penal Code; and f) The disputed precautionary measure “bec[ame] an anticipated sanction[,] and consequently violated Article 22 [of the Convention] in relation to Article 8, paragraphs 1 and 2,” thereof, and the obligation to adopt domestic legislative measures, all in violation of Article 1(1) of the American Convention. Arguments of the State 112. Regarding Article 22 of the Convention, the State argued that: a) The measure adopted by the Paraguayan courts was ordered as a precautionary measure and following the sentence handed down by the court of first instance. The restriction sought “to ensure that the wrongdoer remained subject to the proceedings.” However, Mr. Canese’s restriction to leave the country was not absolute, as the alleged victim acknowledged expressly in his statement before the Inter-American Court during the public hearing. Also, “it was the only measure adopted by the Paraguayan courts throughout the whole criminal proceeding.” “When denying [permission to leave national territory], it was acting in accordance with [the ...] 1890 Code of Criminal Procedure [...] and none of its provisions established alternate or substitute measures to preventive detention that would have a less onerous effect on the quality of life of those accused of punishable acts. This was only rectified by the adoption and implementation of the new Code of Criminal Procedure or Act No. 1286/98;” b) On one occasion when Mr. Canese requested permission to leave the country, he offered “a material surety, with capital assets, as a precaution against failing to return”; an offer that was rejected. “The rejection of [this] offer shows that the courts considered the capital assets surety to be insufficient;” c) “It would be unjust to sanction the State [...] for the alleged failure to comply with [Article] 22 of the American Convention, because the State [...] has adapted the precautionary measures regime to the minimum standards