defendant using less harmful measures to ensure appearance at trial, rather than using deprivation of liberty. 55 In accordance with the aforementioned article, the detained person has the right “to trial within a reasonable time or to be released.” Thus, if a person continues to be preventively deprived of liberty and the proceedings are not completed within a reasonable amount of time, Article 7(5) of the Convention is violated. 87. This Court notes that there is no record of procedural steps between September 13, 1995, when the prosecutor was asked to issue an opinion on the case, and September 30, 1996, when the preliminary proceedings were closed. In that action, the prosecutor was notified so that he could issue an opinion, which was produced over five months later. Similarly, more than a year and eight months passed between the opinion being issued on March 4, 1997, and the hearing being held on December 1, 1998, because the hearing was postponed several times. This shows that, although that Mr. Carranza was deprived of his liberty, there were delays that totaled close to three years out of the approximately four years his criminal trial took starting from the time of his apprehension. There is no justification for these periods of inactivity, especially considering that Mr. Carranza was preventively deprived of his liberty, which should have prompted the legal authorities to conduct his trial with the utmost speed. 88. Because of this, the Court concludes that the State violated Article 7(5) of the Convention. B.4 Presumption of innocence 89. Given the presumption of innocence, guaranteed in Article 8(2) of the Convention, it is a general rule that the defendant shall not be deprived of liberty while on trial. 56 As previously noted, depriving a person of their liberty beyond a reasonable time to achieve the purposes that justify their detention would be tantamount to anticipating a sentence, a violation of the presumption of innocence (supra para. 67). 90. This Court has determined that the order for the preventive detention of Mr. Carranza, as well as the continuation of said detention, were arbitrary. Therefore, prolonging the deprivation of liberty until the time of sentencing was equivalent to anticipating a sentence, in violation of the presumption of innocence. The State thus violated Mr. Carranza’s right to be presumed innocent, enshrined in Article 8(2), in conjunction with Article 1(1), of the Convention. B.5 Length of the criminal trial 91. What remains to be examined is whether the requirement that the proceedings take place within a “reasonable time,” which is one of the judicial guarantees set forth in Article 8(1) of the Convention, was met. 92. This Court has noted that in criminal proceedings, the reasonableness of the time taken must be assessed in relation to the total duration of the trial, from the first 55 Cf. Case of Amrhein et al. v. Costa Rica, para. 361, and Case of Jenkins v. Argentina, para. 84. 56 Cf. Case of López Álvarez v. Honduras, para. 67, and Case of Jenkins v. Argentina, para. 72. 21