that, in this case, less harmful means could have been used for the traffic control sought and to avoid a violent pursuit;130 for example, by setting up traffic controls, with barricades, speed bumps, tire puncturing devices, and/or cameras that permit the non-violent recording and identification of those involved and an improved control of the flow of traffic in the area. Mainly, measures that are in keeping with the daily transit of migrants in the area. Moreover, the body of evidence reveals that the same yellow truck that transported the presumed victims had been detained on March 28, 2000, a few months before the event, having been surprised by agents transporting 50 undocumented Haitian nationals in the section of Santa Maria, Montecristi jurisdiction.131 89. In short, the State could have established less extreme measures to achieve the same end. Even to counter the alleged trafficking of drugs or weapons, the State failed to demonstrate the implementation of an operation designed for that purpose; to the contrary, the State’s actions revealed the lack of planning, training, and organization, which resulted in extremely disproportionate measures taken by military agents. In this regard, the Court has considered that “whenever the use of force [by State agents] has resulted in the death of or injuries to one or more individuals, the State has the obligation to provide a satisfactory and convincing explanation of the events and to disprove the arguments concerning its responsibility, with appropriate probative elements,”132 and this has not occurred in the instant case. 90. The foregoing reveals the absence of clear regulations and a public policy concerning prevention of the use of force and implementation of non-lethal means of deterrence with appropriate defensive equipment to handle this type of situation133 (supra para. 80). 91. In conclusion, neither the legality nor the absolute necessity of the lethal use of force during the pursuit has been proved, because the State was not preventing an attack or imminent danger.134 Consequently, the serious situation that occurred was the result, at least by negligence, of the disproportionate use of force that can be attributed to the State owing to the acts of law enforcement officials. In addition, the Court observes that, in the context of discrimination against migrants, the use of excessive force in the case revealed the failure to implement reasonable and appropriate measures to deal with this situation to the detriment of this group of Haitians. b) Arbitrary deprivation of life 92. The Court has established that when State agents use unlawful, excessive, or disproportionate force, as in this case, leading to loss of life, it is considered an arbitrary deprivation of life.135 Consequently, the death of four people from gunshot wounds occurring during the pursuit of the vehicle (supra para. 48) constituted arbitrary deprivations of life attributable to the State to the detriment of Fritz Alce, Ilfaudia Dorzema, Nadege Dorzema and Máximo Rubén de Jesús Espinal. 130 For example, the following regulations: Law 29166 of the Republic of Peru, entitled “Law establishing rules for the use of force by members of the Armed Forces on national territory” and the “Law that regulates the use of force of public security agencies of the Federal District” of the United Mexican States. Also, the “Manual of norms and procedures for the progressive and differentiated use of force by the police” of the Bolivarian Republic of Venezuela; “A National Use of Force Framework” of Canada; and the “Use of Force by Seattle Police Officers” of the United States of America. 131 Cf. Record of the dispatch of a vehicle of March 29, 2000 (file of annexes to the merits report, tome I, folios 848 and 849). 132 Cf. Case of Zambrano Vélez v. Ecuador. Merits, reparations and costs. Judgment of July 4, 2007. Series C No. 166, para. 108, and Case of Montero Aranguren et al. (Retén de Catia) v. Venezuela, supra, para. 80. 133 Cf. ECHR. Case of Makaratzis v. Greece. Judgment, 20 December 2004, paras. 66 to 70. 134 Principles on the Use of Force, Principles Nos. 4 and 9. 135 Cf. Case of the Barrios Family v. Venezuela, supra, para. 49 29