31 91. Consequently, freedom of expression is necessary for the work of labor unions, to protect labor rights and to further legitimate interests and improve conditions, because, without this right, such organizations would be ineffective and devoid of purpose. 117 92. The Court has also established that the obligation to ensure the rights recognized in the Convention presupposes positive obligations for the State to protect rights, even in the private sphere.118 In cases such as this one, the competent administrative or judicial authorities have the obligation to monitor whether acts or decisions in the private sphere have consequences on fundamental rights, and whether they are in conformity with domestic law and the State’s international obligations. To the contrary, the State must remedy the violation of these rights and protect them adequately. 93. In this regard, the Court has recognized that “in the broad terms of the American Convention, freedom of expression may also be affected without the direct intervention of State actions.”119 In the case of freedom of expression, its real and effective exercise does not depend merely on the State’s obligation to abstain from any interference, but may call for positive measures of protection, including in the relationships between individuals. Indeed, in certain cases, the State has the positive obligation to protect the right to freedom of expression, even from attacks by private individuals.120 94. This is why, in the area of labor, the State’s responsibility may arise in the situation in which domestic law, as interpreted in final instance by the domestic jurisdictional organ, validates a violation of the right of the appellant, so that, ultimately, the penalty is a result of the decision of the national court, and this may entail an internationally wrongful act. 95. In this regard, the European Court of Human Rights has indicated that Article 10 of the European Convention (Freedom of Expression) prevails not only in relations between employer and employee when these are governed by public law, but may also apply when these relations are governed by private law.121 In particular, in application of the protection of freedom of expression in labor contexts between private individuals, the European Court has analyzed whether interference in this right may be attributed to court decisions that ratify dismissal or another penalty.122 The European Court of Human Rights has recognized in its case law that the right to freedom of expression protects the right of “members of a trade union […] to express their demands by which they seek to improve the situation of workers in their company.” According to the European Court, the freedom of expression of labor unions and their leaders is an essential means of action, without which they would lose their effectiveness and purpose. ECHR, Case of Vereinigung Demokratischer Soldaten Österreichs and Berthold Gubi v. Austria, No. 15153/89. Judgment of December 19, 1994 and ECHR, Case of Palomo Sánchez and Others v. Spain, [GS] No. 28955/06, 28957/06, 28959/06 and 28964/06. Judgment of September 12, 2011, para. 56. 117 Cf. Case of Velásquez Rodríguez v. Honduras. Merits, supra, para. 166, and Case of Vásquez Durand et al. v. Ecuador. Preliminary objections, merits, reparations and costs. Judgment of February 15, 2017. Series C. No. 332, para. 141. 118 Compulsory Membership of an Association Prescribed by Law for the Practice of Journalism, OC-5/85, supra, para. 56, and Cf. Case of Granier et al. v. Venezuela, supra, para. 143. 119 Cf. Case of Ríos et al. v. Venezuela. Preliminary objections, merits, reparations and costs. Judgment of January 28, 2009. Series C No. 194, para. 107; Case of Perozo et al. v. Venezuela. Preliminary objections, merits, reparations and costs. Judgment of January 28, 2009. Series C No. 195, para. 118; Case of Manuel Cepeda Vargas v. Colombia. Preliminary objections, merits, reparations and costs. Judgment of May 26, 2010, para. 172. Similarly, ECHR, Case of Palomo Sánchez and Others v. Spain [GS], supra, para. 59; Case of Fuentes Bobo v. Spain, No. 39293/98. Judgment of February 29, 2000, para. 38; Case of Özgür Gündem v. Turkey, No. 23144/1993. Judgment of March 16, 2000, paras. 43 to 50, and Case of Dink et al. v. Turkey, No. 2668/2007, 6102/2008, 30079/2008, 7072/2009 and 7124/2009. Judgment of September 14, 2010, para. 106. 120 Cf. ECHR, Case of Fuentes Bobo v. Spain, supra, para. 38, mutatis mutandis, Case of Schmidt and Dahlström v. Sweden, No. 5589/72, Judgment of February 6, 1976, para. 33. 121 122 Cf. ECHR, Case of Khurshid Mustafa and Tarzibachi v. Sweden, No. 23883/06. Judgment of December 16, 2008,