sponsorship, or when members of the government, or persons with ties to the government, have attempted to obstruct the investigation. 129. This investigation necessarily involves taking account of the patterns of action of these power structures. As can be seen from the case file, the crimes against Jineth Bedoya were executed with a high level of planning, reflected in the acts leading up to the execution of the crime, the threats made to the victim, and the place where the events occurred. The IACHR reiterates that crimes against journalists on account of their profession are selective crimes, and therefore cannot be investigated as ordinary or traditional crimes. These crimes reflect a plan or strategy designed by a criminal organization, network, or power structure, the execution of which aims to cause the death of an individual because of the practice of journalism, to silence him or her, to provoke fear, and ultimately to curtail the right to freedom of expression. Consequently, the obligation to investigate and prosecute these types of crimes with due diligence has specific characteristics. It is an obligation of strict due diligence, which in this case is also heightened if the violence against journalists is part of a context of conflict or massive violations of rights. 130. In view of the foregoing, the IACHR considers that the measures taken to move the investigation forward have not been adequate and sufficient to satisfy the State's obligation to conduct an exhaustive and diligent investigation, given the seriousness of the crime under investigation and the heightened obligations in this area. This could have had a strong chilling effect on the exercise of freedom of expression not only by the journalist, but also by her team and by Colombian society as a whole, with obvious consequences for democratic discourse in the country. Reasonable time period 131. In complying with their duty to pursue justice for acts of violence against journalists, States have an obligation to ensure that criminal investigations and prosecutions are carried out within a reasonable period of time. In this regard, the Inter-American Court has established that excessive delay in the investigation of acts of violence can constitute a per se violation of the right to a fair trial. 236 The authorities responsible for the investigation should conduct the proceedings expeditiously, avoiding unwarranted delays or hindrances that lead to impunity and violate the due judicial protection of rights. 237 132. From its initiation in 2000, the investigation has spanned more than 18 years. The State argued that this delay is not attributable to the conduct of the authorities, but to the complexity of the case. 133. The IACHR observes that during the first 11 years the investigation showed long periods of inactivity and no results. As the petitioner asserts, there were extensive stretches of time during those years, sometimes up to 19 consecutive months, in which the authorities leading the investigation did not undertake or order any investigative proceedings. The investigation was spurred on after journalist Jineth Bedoya became a civil party to the case in 2011, which coincides with the filing of this petition to the Commission for its consideration and with the launch of the “No Es Hora De Callar” [“It’s No Time to Be Quiet”] campaign. Nevertheless, even after that, the Prosecutor’s Office took at least five years to name three individuals as suspects in the case and obtain their conviction as the direct perpetrators. The investigation remains open with respect to other direct perpetrators and masterminds, including an investigation into the possible active or passive participation of State agents in the events of May 25, 2000. Therefore, the IACHR concludes that the investigation of the crime against journalist Jineth Bedoya Lima has not been carried out within a reasonable period of time. 134. In light of all of the above considerations, the IACHR concludes that the State has violated the rights to a fair trial and to judicial protection established in Articles 8.1 and 25.1 of the American Convention, I/A Court H.R. Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C, No. 136. Para. 85; I/A Court H.R. Case of the Moiwana Community v. Suriname. Preliminary Objections, Merits, Reparations and Costs. Judgment of June 15, 2005. Series C, No. 124. Para. 160. 237 I/A Court H.R. Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C, No. 136. Para. 85. 236 33

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