1. General Considerations 81. According to the consistent case law of the organs of the inter-American system, as a result of the protection granted by Articles 8 and 25 of the Convention and the general obligations contained in article 1(1) thereof, the States have a duty to provide effective judicial recourses to the victims of human rights violations that must be substantiated in accordance with the rules of due process of law. 151 That obligation, which relates to means rather than to results, must be assumed by the State as its own legal duty and not as a mere formality preordained to be ineffective.152 82. The Court has held that when it comes to the investigation of the death of a person who was in State custody, as in this case, the relevant authorities "have a duty to initiate ex officio and without delay, a serious, impartial, and effective investigation." According to its jurisprudence, “this investigation must be conducted using all available legal means to determine the truth and to investigate, prosecute and punish all those responsible for the facts, especially when State agents are or may be involved.” 153 Thus, the duty to investigate must be undertaken in a serious, have an objective, and be assumed by the State as its own legal duty, not as a step taken by private interests.154 83. In that same vein, in order to ensure due diligence in the conduct of a thorough and impartial investigation of a violent death, including situations that might include State agents, the Commission underscores a number of standards contained in the Minnesota Protocol, an instrument that sets out a number of basic procedures, such as identification of the victim; recovery and preservation of evidentiary material related to the death to aid in any potential prosecution of those responsible; identification of possible witnesses and collection of statements from them concerning the death; determination of the cause, manner, location and time of death, as well as any pattern or practice that may have brought about the death; distinction between natural death, accidental death, suicide and homicide; identification and apprehension of the person(s) involved in the death; and bringing of the suspected perpetrator(s) before a competent court established by law.155 84. Furthermore, under the standards of the aforementioned protocol, it is a generally recognized principle of autopsies in cases of suspicious deaths that the work of forensic personnel, among others, is to help to ensure that the causes and circumstances of the death are clarified so that conclusions may be presented as to the cause of death and the circumstances that contributed to it. Likewise, the Protocol recognizes that there are few cases in which the cause of death can be determined on the basis of the autopsy alone without other additional information about the death; therefore the autopsy report should contain a list of the injuries discovered and offer an interpretation in respect of those injuries. Finally, the Protocol recognizes the particular importance in such autopsies of putting together a record of images of the autopsy, by taking both appropriate photographs for documentation and independent review, and x-rays of the entire body.156 85. Furthermore, with regard to the principle of a reasonable time established in Article 8(1) of the American Convention, the Inter-American Court has established that it is necessary to take into account three elements in order to determine the reasonableness of the time in which the proceedings are held: (a) the complexity of the case; (b) the procedural activity of the party concerned, and (c) the conduct of the judicial state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties. 151 I/A Court H.R., Case of Rodríguez Vera et al. (Persons Disappeared from the Palace of Justice) v. Colombia, Preliminary Objections, Merits, Reparations, and Costs, Judgment of November 14, 2014. Series C. No. 287, par. 435. 152 I/A Court H.R., Case of Velásquez Rodríguez v. Honduras, Merits, Judgment of July 29, 1988. Series C. No. 4, par. 177. 153 I/A Court H.R., Case of Mendoza et al. v. Argentina, Preliminary Objections, Merits and Reparations, Judgment of May 14, 2013. Series C. No. 260, par. 218. See also Cf. Velásquez Rodríguez Case v. Honduras, Merits, pars. 177, and Case of the Santo Domingo Massacre v. Colombia, par. 157. 154 I/A Court H.R., Velásquez Rodríguez Case v. Honduras, Merits, Judgment of July 29, 1988. Series C, No. 6, par. 177. 155 I/A Court H.R., Case of Ortiz Hernández et al. v. Venezuela, Merits, Reparations and Costs, Judgment of August 22, 2017, Series C. No. 338. par. 161. 156 Ibid., pars. 148-182, 255, 264, and 266.