50 for Justice and International Law (CEJIL),82 and the International Human Rights Law Clinic, University of California, Berkeley, Boalt Hall School of Law,83 who have incurred a series of expenses related to the said measures. IX VIOLATION OF ARTICLES 19, 20, 24, 3 AND 18 OF THE AMERICAN CONVENTION IN RELATION ARTICLE 1(1) THEREOF (Rights of the Child, Right to Nationality, Right to Equal Protection, Right to Juridical Personality, Right to a Name, and Obligation to Respect Rights) Arguments of the Commission 110. With regard to Article 19 of the American Convention, the Commission indicated that: (a) The State failed to comply with its international obligations because it did not adopt the necessary measures that took into consideration the superior interest of the child and ensured the protection of Dominican children of Haitian origin, such as the children Dilcia and Violeta; (b) The State disregarded its obligation to protect the children Dilcia and Violeta in accordance with Article 19 of the Convention, by maintaining them in a situation of legal, social and economic vulnerability and marginalization, and failing to ensure their right to nationality, exposing the children to the risk of being expelled from the Dominican Republic, and (c) The State did not comply with its obligation to ensure the right to education, since the child Violeta was prevented from enrolling in day school because she had no birth certificate. 111. that: In relation to Article 20 of the American Convention, The Commission argued (a) The Constitution established ius soli as the principle for acquiring Dominican nationality, and the right to nationality based on having been born on Dominican territory is protected by the Constitution, irrespective of the nationality or legal status of the parents. Any restriction of the right to nationality that is not based on a child’s place of birth directly contradicts this principle; (b) It is unacceptable to describe the alleged victims in this case as “foreigners in transit,” since those who live for 10, 15 or more years in a country cannot be described as transients; 82 Cf. CEJIL expense vouchers in the case of the Yean and Bosico children (file of attachments to the brief with requests and arguments, attachment 54, folios 537 to 728, and file of preliminary objections and possible merits and reparations, tome V, folios 1314 to 1319). 83 Cf. expense vouchers of the International Human Rights Law Clinic in the case of the Yean and Bosico children (file of attachments to the brief with requests and arguments, attachment 57, folios 829 to 852).