intimidation against justice operators, so as to be able to detect patterns and identify the sources of risk with a view to providing appropriate and effective protective measures.157 123. As indicated in the foregoing section, judges have a right to see that they are protected against outside pressure relating to the functions they perform that may impair their right to life and personal integrity as well as the independent and impartial performance of their work. Derived from those rights is a corresponding duty of the State to adopt the measures needed to ensure effective protection of judges against the many different forms of outside pressure that may be exerted. In addition, once the State becomes aware of such circumstances, it has the obligation to initiate an investigation with all due diligence, within a reasonable period of time, while at the same time respecting the other guarantees of due process, in order to shed light on the aforementioned pressures, detect where they come from, including possible risks to the life of personal integrity of the judge in questions, and single out and punish those responsible. The Commission considers that there is a crucial link between proper investigation of the acts of aggression, threats, harassment, or intimidation to which a judge may be subjected and their dismantlement, including the implementation of protective measures that are genuinely tailored to dealing with specific pressures and the sources thereof. 124. In the instant cases, the parties do not dispute the complaints lodged with respect to the various threats, acts of aggression, harassment, and intimidation to which María Eugenia Villaseñor was subjected in her capacity as a judge. Accordingly, the Commission stresses that, while she participated in a number of judicial proceedings between 1991 and 2012, Mrs. Villaseñor complained through various channels that she was the victim of (i) house searches; (ii) death threats by phone, text messages and even by unknown persons outside her home; (iii) an attempt to kidnap her daughter and to kidnap one of the policemen guarding her home, the beating of her sister and death of her niece after she was hit by a car; (iv) theft, on more than one occasion, of her personal information; (v) attempts to break into her car, and destruction of tires and a telephone line; and (vi) statements and communications from unidentified persons denigrating her work as a judge. 125. As described above in the section on proven facts, those denunciations were filed in a context of insecurity for judges in Guatemala, particularly in relation to the hearing of cases of human rights committed by State agents. That context has been described not only by the IACHR, but also by other international organizations, such as the United Nations Human Rights Committee, as well as by United Nations Special Rapporteurs on the Independence of Judges and Lawyers. 126. While it is familiar with that context and with the complaints filed by judge María Eugenia Villaseñor, the Commission has no information at all indicating that steps have been taken to investigate them. The Commission underscores the fact that in her written communication of May 2014, Mrs. Villaseñor maintained that at the time of her communication the investigations were at an initial stage and those responsible had not been identified. The State did not contest that information. Consequently, the Commission concludes that the complaints and the information that the State had regarding Mrs. Villaseñor 's situation were not duly investigated with a view to identifying sources of risk, helping to eradicate them, singling out those responsible, and imposing appropriate sanctions. 127. The IACHR considers that the lack of an effective investigative response is exacerbated when one takes into account Mrs. Villaseñor 's participation as a judge, in the performance of a public function, in various proceedings relating to human rights violations or crimes against property allegedly committed by State agents, including military personnel and policemen. In fact, the Commission underscores the following circumstantial evidence of a possible link between state agents and the various outside pressures to which judge Villaseñor was subjected: (i) the two men who attempted to raid her home in June 1994 appeared to be soldiers, according to Mrs. Villaseñor 's account; (ii) security agent Miguel Pacheco, who was kidnapped outside Mrs. Villaseñor 's home, stated that he was interrogated about her ties to the sister of Myrna Mack, 157 IACHRGuarantees for the Independence of Justice Operators. Towards strengthening access to justice and the rule of law in the Americas. December 5, 2013, par. 165. 22

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