75. This Court considers that, under the rule of law, the independence of all judges and, in particular, that of constitutional judges, must be guaranteed owing to the nature of the matters submitted to their consideration. As the European Court has indicated, the independence of any judge presumes that there is an appropriate appointment process,115 a fixed term in the position,116 and a guarantee against external pressures.117 […] 77. Regarding the exercise of the authority of Congress to conduct impeachment proceedings, which engages the responsibility of a public official, the Court believes that it should be recalled that any person subject to a proceeding of any nature before an organ of the State must be guaranteed that this organ is competent, independent and impartial and that it acts in accordance with the procedure established by law for hearing and deciding the case submitted to it. (Underlining added) 83. The actual members of the ICourtHR have ratified what was stated in the 2001 precedent, which, in my opinion, has great significance today if we consider a continuation in the line of case law on due process under the Convention that the Inter-American Court has been developing since then; so that the rights established in Article 8(2) of the American Convention — in principle addressed at the “minimum guarantees” in criminal proceedings – also extend to the civil, labor, fiscal, or any other order; in other words, the minimum guarantees established in Article 8(2) of the American Convention are applicable to those orders also and, consequently, in that type of matter also there is, “in general,” a right to the due process of law that applies in criminal matters. 118 To reinforce this position, in the Judgment in the instant case, 119 the Inter-American Court also based itself on the case of Baena Ricardo et al. v. Panama, which indicates, inter alia, “that the series of minimum guarantees established in paragraph 2 of Article 8 of the Convention apply to the spheres mentioned in paragraph 1 of this article; that is the determination of rights and obligations of a civil, labor, fiscal, or any other nature. This reveals the broad scope of due process; the individual has the right to due process understood in the terms of Article 8(1) and 8(2), in both criminal matters and in all these other spheres.”120 84. It should be stressed that, in the Judgment that prompts this opinion, the ICourtHR does not make a specific analysis of the meaning that the 2001 precedent attributes to the expression “in general,”121, which is fundamental in order to determine whether each and every one of the “minimum guarantees” established in Article 8(2) apply to spheres other than criminal matters and, specifically, if they all apply to impeachment. However, the Judgment declared the violation of Article 8(2) (for different forms of adequate defense) and 8(4) (the guarantee of ne bis in idem). I consider that, in the future, the InterAmerican Court will have to clarify, precisely, the full applicability – or case by case – of the 115 Cf. Eur. Court H.R., Langborger case, decision of 27 January 1989, Series A no. 155, para. 32, and Eur. Court H.R., Campbell and Fell, supra note 47, para. 78. 116 Cf. Eur. Court H.R., Langborger case, supra note 51, para. 32; Eur. Court H.R., Campbell and Fell, supra note 47, para. 78; and Eur. Court H.R., Le Compte, Van Leuven and De Meyere, judgement of 23 June 198I, Series A no. 43, para. 55. 117 Cf. Eur. Court H.R., Langborger case, supra note 51, para. 32; Eur. Court H.R., Campbell and Fell, supra note 47, para. 78, and Eur. Court H.R., Piersack judgement of I October 1982, Series A no. 53, para. 27. 118 Case of the Constitutional Court v. Peru. Merits, reparations and costs. Judgment of January 31, 2001. Series C No. 71, para. 70. 119 Para. 167 of the Judgment. 120 Case of Baena Ricardo et al. v. Panama. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 125. 121 Case of the Constitutional Court v. Peru. Merits, reparations and costs. Judgment of January 31, 2001. Series C No. 71, para. 70. 23