25
MECHANISMS TO MEASURE THE EFFECTIVENESS OF
INTERNATIONAL TRIBUNALS AND ITS RELATIONSHIP WITH
JUDGEMENT COMPLIANCE
María Helena Carbonell-Yánez
Instituto de Altos Estudios Nacionales
Diajeng Wulan Christianti
Lecturer at Faculty of Law, UNPAD (Padjadjaran University), Indonesia
ABSTRACT
En los últimos 80 años, los tribunales
internacionales se han proliferado para
abordar diversas disputas, que van desde
asuntos territoriales hasta comerciales. Este
desarrollo ha generado un debate entre dos
tendencias opuestas: una que aboga por el
fortalecimiento de los tribunales
internacionales y otra que busca socavar su
influencia. Ambas perspectivas se basan en
la premisa de que estos tribunales son poco
probables de desaparecer y pueden jugar un
papel significativo en los asuntos
internacionales. Este artículo presenta un
análisis crítico de la efectividad de los
tribunales internacionales de derechos
humanos, centrándose particularmente en
el cumplimiento de sus sentencias. Se
argumenta que la efectividad es el criterio
esencial para evaluar el desempeño de estas
instituciones, ya que su verdadero impacto
solo puede medirse a través del grado en
que sus decisiones son implementadas por
los Estados parte. Destaca la necesidad de
un enfoque basado en el cumplimiento para
evaluar el desempeño de los tribunales,
utilizando la Corte IDH como caso central.
Este enfoque pone de relieve la tensión
entre el idealismo y la realidad en cuanto a
garantizar el cumplimiento de las
sentencias en materia de derechos
humanos.
RESUMEN
In the last 80 years, international tribunals have
proliferated to address various disputes, ranging
from territorial to commercial matters. This
development has sparked a debate between two
opposing tendencies: one advocating for the
strengthening of international tribunals and the
other seeking to undermine their influence. Both
views are based on the understanding that these
tribunals are unlikely to disappear and can play
significant roles in international affairs,
especially in the context of human rights.
This paper presents a critical analysis of the
effectiveness of international human rights
tribunals, focusing particularly on the
compliance with their judgments.
It argues that effectiveness is the essential
criterion for evaluating the performance of these
institutions, as their true impact can only be
measured through the extent to which their
decisions are implemented by State parties. The
analysis emphasizes the need for a compliance-
based approach to assess the performance of
tribunals, using the Inter-American Human
Rights Court as a central case study. This
approach sheds light on the tension between
idealism and reality in ensuring compliance with
international human rights rulings.
Mechanisms to measure the effectiveness of International Tribunals
26
PALABRAS CLAVE:
tribunales internacionales; acercamiento de
cumplimiento de los objetivos; eficacia; Corte Interamericana de Derechos
Humanos
KEYWORDS:
International tribunals; compliance-based approach;
effectiveness; Inter-American Court of Human Rights
JEL CODE:
K33; K10
Revista Facultad de Jurisprudencia No.16
27
INTRODUCTION
The international system created to solve international controversies is a
mechanism to maintain peace and friendly relations between States. During the second
half of the XX century, after the traumatic events of Second World War, the international
community faced a new phenomenon: the proliferation of international tribunals in
different regional, subregional and universal scenarios. This occurrence was due to
several factor such as the expansion of the material regulation scope of Public
International Law; to the increased number of economical regional integration
agreements; amongst others. (Alter, 2008, pp. 33–34; Guzmán, 2008, p. 173; Jodoin,
2010, p. 1; Linton & Kebede Tiba, 2009, pp. 407–408; Romano, 1999, pp. 728–736)
Authors such as Shany assert that there has been a change in the balance of
international power that grants more weight to the judicial Branch in comparison to
“legislative” and “executive” branches of the international community. (Shany, 2016, p.
1) Linton and Kebede Tiba maintain that we can identify a system (of jurisdictional
nature) for the peaceful settlement of international disputes that has reached a high degree
of maturity. (Linton & Kebede Tiba, 2009, p. 411) This system is in the hands of
international tribunals and, according to Sorensen, trusting their resolutions to determine
the applicable law has become important and common in the international relations
system. (Sorensen, 2011, p. 178)
The consolidation of international tribunals can be analyzed from two different
perspectives. The first one has a formal and juridical approach. Posner and Yoo argue that
the tribunals are growing more and more powerful keeping in mind that accepting their
jurisdiction is becoming more and more mandatory. This argument doesn’t seem to hold
regarding international human rights tribunals except for the European Court of Human
Rights (“ECtHR”)
1
. For the African Court on Human and Peoples’ Rights (“ACtHPR”)
and the Inter-American Court of Human Rights (“ICtHR”) its jurisdiction is based on the
State’s volition.
1
The ECtHR, after the entry into force of Additional Protocol No. 11, became the only international
tribunal with a mandatory jurisdiction to all member States of the Council of Europe.
Mechanisms to measure the effectiveness of International Tribunals
28
The second approach justifies this consolidation of international tribunals on the
expansion of the material regulation scope of Public International Law. This phenomenon
brings a fragmentation which is reflected on the rise of different tribunals, each with its
own specific set of rules and tasks. This shows a lack of an understanding to create a
single centralized justice administration system. (Posner & Yoo, 2005, p. 11)
Tomuschat explains that “(i)nternational courts and tribunals (“ICT”) are
permanent judicial bodies made up of independent judges who are entrusted with
adjudicating international disputes on the basis of international law according to a pre-
determined set of rules of procedure and rendering decisions which are binding on the
parties (Judicial Settlement of International Disputes).” (Alter, 2008, p. 34; Sorensen,
2011; Tomuschat, 2008, p. 179; Voeten, 2012, p. 422)
Romano adds two additional criteria: that the ICT was not created to address a
particular issue (no more ad hoc tribunals), and that it solves disputes where at least one
of the parties is a State. (Romano, 1999, p. 715) Guzmán, on the other hand, tries to relate
international tribunals to national ones; (Guzmán, 2008, p. 185) However this obviates
some substantial differences between national and international courts.
As has been said before, these international courts and tribunals (“ICT”) solve
internation disputes applying a wide range of Public International Law rules regarding
topics as taxes, boundaries, human rights, amongst others. They not only interpret the
existing rules but also developing their scope through their judgements. Having this in
mind, the second criteria added by Romano seems to fade in a context where atypical
subjects on International Law acquire rights and obligations, and, in many cases, have
locus standi in front of international bodies (capacity to appear before the court).
In this scenario where ICT far from disappearing tend to become stronger, it is
necessary to analyze their work to determine their effectiveness and the benefits of
maintaining organs that, in many cases, imply high costs for the international community.
Usually, research on ICT are centered on their creation and design (from a historical and
procedural perspective) or on their working and relationship with other bodies from a
judicial independence perspective (other ICT that solve controversies on the same area or
Revista Facultad de Jurisprudencia No.16
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with the same parties) (Jodoin, 2010, pp. 1–2).
This paper is focused on the effectiveness of ICT and the relation with compliance
with its judgements. I maintain that effectiveness is essential to measure its performance
regarding States and those who use it. This has already been addressed by International
Relations scientists. But legal doctrine has some methodological limitations because there
is no clear definition of effectiveness, in many cases, confusing it with related but
different concepts (Pellet, 2009; Shany, 2016).
WHAT IS EFFECTIVENESS?
Nowadays, there are two major approaches from different theorical frameworks
that, we consider, don’t allow a global analysis on the effectiveness of international
tribunals. On one side, there are those authors who analyze them through the relation
between ICT and some of the authorized actors, such as States, persons, and companies.
On the other hand, other authors identify the effectiveness of ICT as the compliance with
their judgements. On the first group we can find Posner and Yoo who emphasize the use
that the States make of those tribunals and their structure emphasizing judicial
independence (they even propose a series of mechanisms to measure that independence),
as central to assess the effectiveness of ICT. They argue that States create these entities
because it is in their interest to have somebody to deliver a somewhat neutral analysis on
the facts and the applicable law. Even if the international tribunal renders a “negative”
decision, the benefits of having independent mechanisms to solve international
controversies will still be greater than the loses for the “loosing” State. The authors
conclude that non-independent tribunals, those controlled by the States, would be
effective because they will be used more because they will render more favorable
judgements and will not risk international cooperation. (Posner & Yoo, 2005, pp. 15–18,
21, 26–27)
On the other hand, Helfer and Slaughter criticize this argument mentioning some
methodological problems in the definition of both the independent and dependent
variables of their study. They conclude that independent tribunals (outside the control of
Mechanisms to measure the effectiveness of International Tribunals
30
the State of on which they exert limited control) will be effective, admitting that this is an
“elusive” concept that cannot me measure simply through judicial independence as
argued by Posner and Yoo. (Helfer & Slaughter, 2005)
Regarding the effectiveness of international human rights tribunals, it is necessary
to make two initial remarks. The first one is related to the limited juridical personality
(recognition as a person before the law) of the human being in an international level and
the restricted access to these tribunals. Only in the European Human Rights System,
persons can appear directly before the ECtHR. In the African System, a person can do it
only if the State has accepted that possibility according to article 34(6) of the Additional
Protocol 1 to the African Charter. In the Interamerican System, a person cannot present a
case before the IACtHR. Having in mind these limitations, regarding the effectiveness of
international human rights tribunals as identical to the use the victims make of them
presents a very narrow definition of effectiveness.
The second initial remark is related to the first one and addresses one of the
consequences of using the narrow definition mentioned above. By employing “use” as a
synonym of “effectiveness”, multiple elements are left behind. Amongst them is the fact
that not all the different forums for human rights protection will issue a decision similar
in nature (i.e. mandatory or not); the lack of knowledge of all the available forums by
victims; and the requisite of exhaustion on local remedies. Guzmán seems to share this
opinion when affirming that usage rates are not an indicator top measure the tribunal’s
effectiveness nor the impact it may have on the conduct of the State. (Guzmán, 2008, p.
187)
Helfer, Slaughter and Pellet (Pellet, 2009) seem to navigate between the first
group of authors and one that regard the compliance with treaties or judgements issued
by a tribunal as identical to its effectiveness. So, when defining effectiveness, they refer
to the tribunal’s capacity to force, directly or indirectly (through external pressure), to the
“losing” State to comply with its decision through the modification of its conduct .(Helfer
& Slaughter, 2005, pp. 917–919) It seems that they favor an equivalence (or a very close
relation at least) between compliance and the effectiveness of an international tribunal.
Other authors such as Jacobson, Brown Weiss, Rodríguez Rescia, Baillet and
Revista Facultad de Jurisprudencia No.16
31
Hillebrecht base their arguments on a definition of effectiveness that implies a very close
relation to compliance with its decisions. (Baillet, 2013; Hillebrecht, 2009; Jacobson &
Brown Weiss, 2000; Rodríguez Rescia, 1997) For Hillebrecht, compliance is essential for
legitimacy, the moral authority and effectiveness of international tribunals. She asserts
that a tribunal whose decisions are not complied with can’t be considered as legitimate
and, in the long run, won’t be effective. On the other hand, Jacobson and Brown Weiss,
in a study of compliance with environmental international agreements, almost use
effectiveness and compliance as synonyms, without suggesting an independent definition
of the first one but defining it in relation to compliance of the obligations stated on the
primary norma (whether from a treaty of international customary law). However, as we
will later see, the effectiveness of the international tribunal can’t solely be understood as
compliance with its judgements. This idea seems to be shared by Jacoby and Hawkins
(Hawkins & Jacoby, 2010, pp. 39–41), Guzmán(Guzmán, 2008, p. 187) (parcialy), Alter
(Alter, 2008, p. 52), and Shany (Shany, 2004, 2016).
On the other hand, González-Salsberg seems to partially agree with this position
but considers and additional element: the relation between compliance with the tribunal’s
decisions and the objectives of the system on which said tribunal is based upon. Even if
he mentions this element he doesn’t determine the causal connection between the two.
For him, the effectiveness can be understood as the degree on which these institutions
play a crucial role on the conduct of international actors (such as States), but he asserts
that it should be measured based on the compliance of the ITC decisions. (González-
Salzberg, 2010, p. 121) As we will soon see, the effectiveness of and international
tribunal can’t be reduced to compliance with its judgements.
In other branches of social sciences (other than Law) there are theorical
frameworks to measure the effectiveness of an organization (national or international).
Nonetheless, there is no consensus. It is necessary to mention there is very little on ITC
and that academic research that analyze this topic tend to miss providing a clear
theoretical framework and the measuring parameters. In the following paragraphs, we
will review the main theories regarding measuring effectiveness of an organization; the
goal-based approach, the open system approach, and the resources based approach
Mechanisms to measure the effectiveness of International Tribunals
32
(Ashraf & Abd Kadir, 2012; Balduck & Buelens, 2008). (Shany, 2016, p. 16)
Additionally, we can also identify the model-based approach, and the model based on the
constituencies. In each section we will apply the main elements of the theoretical
approach to international human rights tribunals to identify their strengths and
weaknesses.
On the one hand, the open system approach considers an organization to be
effective when it acts in a balanced and sustainable way with its environment (controlling
it, to a certain extent). (Etzioni, 1960, pp. 261, 273; Shany, 2016, p. 14)
In this model, Martz says, for an organization to be effective it must acquire and
transform inputs or contributions into products or services that stakeholders consider
valuable. (Martz, 2008, p. 37) In applying this model to international courts, the inputs
correspond to the cases submitted to them, and the final products will be the sentences
issued by said court.
It is argued that this model has two shortcomings in the case of human rights
courts. The first is that an effective court will be one that issues judgments responding to
the interests of the parties involved, without taking into account their subsequent
compliance. The right to access to justice does not end with the mere issuance of a
judgment, but the judicial process will culminate with its execution. (Caso Acevedo
Buendía y otros (“Cesantes y Jubilados de la Contraloría”) Vs. Perú. Excepción
Preliminar, Fondo, Reparaciones y Costas, 2009; Caso Hornsby Vs. Grecia. Fondo, 1997)
If only the issuance of the sentence were taken into account, the findings would not reflect
the reality of the administration of justice but would qualify a court as effective only based
on the number of sentences issued. Another shortcoming of the model is that it does not
take into account the primary beneficiaries of the organization because, according to
Martz, they are not fundamental elements for assessing its effectiveness. (Martz, 2008, p.
41) This does not fit into the study of international human rights tribunals, since it is
necessary to keep in mind that the primary beneficiaries are the rights holders. Without
taking them into account in the evaluation process, it is not possible to evaluate their
effectiveness. Similarly, it will be useful for the State to have a system that reviews when
it has fulfilled its obligations in relation to the victims. In view of the above, this approach
Revista Facultad de Jurisprudencia No.16
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could be viable for the evaluation of the effectiveness of interstate international tribunals,
but not for international human rights courts.
On the other hand, the approach focused on a system of resources, the most widely
accepted today (Balduck & Buelens, 2008, p. 5), considers the ability to obtain scarce and
valuable resources and the survival of the organization as parameters to measure its
effectiveness (Ashraf & Abd Kadir, 2012, p. 81). Regarding this approach, it should be
noted that, in the case of international courts (whatever their ratione materiae
competence), their survival is not equivalent to effectiveness (Shany, 2016, p. 16). The
starting point, says Etzioni, is not the objective of the court itself but the process of
achieving a certain objective through an appropriate use of the available resources.
However, the author argues, many resources are allocated to activities or functions that
do not necessarily seek to achieve the organization's objectives. (Etzioni, 1960, p. 262) It
may be the case that a court is eliminated because it has fulfilled the task entrusted to it
in its founding instrument, not because it is or has been ineffective. This is the case of the
international criminal tribunals of Rwanda and the former Yugoslavia. (United Nations
Security Council, 2010, 2016) Additionally, this approach does not consider external
actors as a fundamental element for its effectiveness since, in this scenario, the
organization (the court) exists as an autonomous entity, independent of external actors.
(Ephraim Yuchtman & Seashore, 1967, p. 897)
As in the previous model, it is argued that there are two shortcomings in its
application to the functioning of human rights courts. In the case of human rights
violations, considering the victims at the merits stage, as well as in determining reparation
measures, is essential. This approach does not consider the victims and their demands
when assessing the effectiveness of the court, since they are configured as actors external
to the organization. Additionally, it evaluates the court's capacity to negotiate and to
acquire scarce and valuable resources (Ephraim Yuchtman & Seashore, 1967, p. 898).
These resources correspond to cases that are submitted to the international human
rights courts. The principle of subsidiarity, a fundamental pillar of the international
system for the protection of human rights, does not effectively allow for measuring its
capacity to negotiate and “acquire” new cases. In the case of the IACtHR, the power to
Mechanisms to measure the effectiveness of International Tribunals
34
refer cases is the exclusive power of the IACtHR (not counting the system of interstate
petitions) and there is no negotiation process in which the former obtains cases from the
latter. Likewise, the element of competence has no meaning in the study of human rights
courts: each one in its region has no one to compete with in the process of “acquiring
cases” since it is the only entity of this nature.
Thirdly, the process-oriented model emphasizes, as its name suggests, the internal
processes and operation of the organization. For Shany, Ashraf, and Abd Kadir,
effectiveness, in this scenario, is understood as a continuous process and not as a final
state. (Ashraf & Abd Kadir, 2012, p. 81; Shany, 2016) This position, despite being based
on the organization's objectives, does not focus on their finite fulfillment, but on the
optimization of a process aimed at that fulfillment. The process-oriented model is based
on three interrelated components: a) the notion of optimization of objectives (not their
fulfillment); b) an open system perspective recognizing that the context limits or prevents
the full fulfillment of certain objectives; and c) the emphasis on human behavior in the
context of the organization. (Martz, 2008, pp. 42–45) One shortcoming of this approach
is that it does not consider external forces that cannot be controlled by the organization.
In this sense, in the case of international courts, political forces, outside their control, are
essential to assess their functioning. Without taking this into account, the findings from
the application of this model will not be complete.
On the other hand, the stakeholders (constituencies) model is based on the interest
that people or groups have in the performance of the organization. (Ashraf & Abd Kadir,
2012, p. 81) An organization will be effective when it can satisfy the preferences of its
“stakeholders”, doing what these people or groups want it to do. We consider some
shortcomings of this approach: one regarding the means used to satisfy these needs; and
the second one, the preference that will be given to certain needs over others.
There is no agreement on this matter, but Martz ventures to present a classification
of constituencies to assess which interests should prevail. Thus, the author divides them
into two groups, each of them composed of people/groups with specific interests that must
be considered. First, those “members” of the organization who act legally on its behalf;
and second, those external actors that are affected by the performance of said
Revista Facultad de Jurisprudencia No.16
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organization. (Martz, 2008, pp. 45–49) An element that differentiates this approach from
those presented above is the importance of the context in which the organization is
anchored, given that the previous approaches leave aside the influence of the context on
the functioning of the object of study.
Taking up Zammuto's point, Martz mentions four models within this approach.
The first of them is the realist one, which recognizes that it is wrong to give preference to
the interests of a particular group because it is considered the only correct one. The second
is the power perspective: the organization should appease those interested parties that
could threaten the survival of the organization. The third is the one founded on social
justice, according to which effectiveness would be based on the extent to which the least
favored interested parties, in our case, the victims of human rights, will be affected as
little as possible by the actions of the court. Finally, the evolutionary perspective proposes
that the effectiveness of the organization should be valued as a continuous and not a finite
process.
Despite these considerations, this approach will value the survival of the
organization as the last criterion, placing emphasis on the second of the elements
mentioned. (Martz, 2008, p. 45) This approach does not allow for an adequate assessment
of international human rights courts since it would place emphasis on the interests of
States (those fundamental actors in the existence of the court) over those of the victims.
Once the different theoretical approaches related to the effectiveness of
organizations and their viability for the case of international human rights courts have
been reviewed, the goal-based approach is proposed as the one that is viable for the study
of ITC.
GOAL-BASED APPROACH TO MEASURE EFFECTIVENESS OF
INTERNATIONAL COURTS AND TRIBUNALS
Another model for assessing the effectiveness of an organization, whatever its
nature (Etzioni, 1960, p. 258), is the goal-based approach. According to this proposal, an
organization that meets its objectives is considered effective, these being part of its design
Mechanisms to measure the effectiveness of International Tribunals
36
and structure (Perrow, 1961; Shany, 2016, p. 14). This model is based on two
assumptions: the first is that these objectives are “specific, measurable and operational”;
and the second is that the main actors in each organization are committed to fulfilling
them. (Ashraf & Abd Kadir, 2012, p. 81; Balduck & Buelens, 2008, p. 4; Martz, 2008,
pp. 32–33) In this case, good faith is presumed in the conduct of the main actors in the
organization when it is considered a “rational and deliberative” entity (Martz, 2008, pp.
32–33)
It is precisely these two premises that are the focus of the main critics of this
model. On one hand, it is argued that the lack of specificity in the design of the objectives
directly affects the criteria for measuring their fulfillment. However, this lack of
specificity is less real than it seems since it is possible to identify the objectives in various
instruments or in the same practice of the institution. On the other hand, there is an alleged
lack of impartiality in the design of the objectives since these reveal the interests of the
main actors (Etzioni, 1960, pp. 258, 274; Martz, 2008, p. 35). In this sense, for Etzioni,
the problem lies in the fact that the so-called “institutional objectives” are nothing more
than the values that observers project onto the unit of analysis. The author goes on to state
that this alleged lack of impartiality is not insurmountable, and mentions that to identify
the objectives, it is necessary to have proof that those are in fact the objectives of the
organization. (Etzioni, 1960, p. 274) This is achieved through, among others, the specific
methodology that seeks to avoid the preferences of those who study the organization.
According to Shany, to measure the fulfillment of the objectives of an
international court and, therefore, measure its effectiveness, a study in three stages is
necessary. The first of these is the identification of the objectives of the court studied; the
second is the definition of measurement indicators, whether qualitative or quantitative;
and the third is the establishment of a causal link between the conduct of the State and
the functioning of a particular court.
HOW TO IDENTIFY THE OBJECTIVES OF AN INTERNATIONAL
TRIBUNAL?
Revista Facultad de Jurisprudencia No.16
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In this section and the next, the types of objectives that exist and the classification
that will be used in the rest of the chapter are defined. In a second stage, the objectives of
international jurisdictional bodies are proposed, with an emphasis on human rights courts.
A traditional proposal, taken up by Perrow, establishes that there are official
objectives and operational objectives. The former are formally established in the
constitutive instruments of the organization being analyzed and, therefore, are abstract
and open-ended. In contrast, operational objectives are those that reflect the specific
policies that the organization effectively prioritizes what the organization is trying to
achieve. Understood as such, they become means to achieve official objectives and are
defined by certain groups within the organization, responding to specific imperatives and
contexts, unlike the former. Perrow points out that these become the unofficial uses that
these groups give to the organization to achieve their own objectives (which do not always
coincide with the official objectives of the organization). The author focuses on these two
types of objectives; however, he admits the possibility that the organization carries out
certain actions with a view to achieving the fulfillment of certain external objectives,
specific to the system in which it is anchored. In this sense, Perrow states, it fulfills an
“adaptive, gratifying, integrative and pattern-maintaining” function that is essential to
achieve the official objectives. (Perrow, 1961, pp. 855–857)
In contrast to this traditional classification, Shany proposes a different one focused
on three criteria from the perspective of the mandate providers (States). This is based on
the fact that, in most international courts
2
, it is the States that create them (they formulate
mandates, finance the court and establish its objectives) and control their operation (they
supervise, issue criteria on their performance and can even dissolve them), which makes
it impossible to ignore them when assessing the effectiveness of such courts. As for the
classification criteria, the author proposes that, depending on the source, the objectives
can be external and internal. (Shany, 2016, pp. 18–19) The former are obligatory as they
come from the principals and are included in the constitutive instruments of the
organization. This means that any change sought must necessarily go through a review of
2
A clarification should be made regarding the ad hoc international criminal tribunals. Although they were
created by resolutions of the UN Security Council, the States (through the SC) remain the ones who control
their operation.
Mechanisms to measure the effectiveness of International Tribunals
38
the instrument, a procedure that is highly cumbersome and slow. On the other hand, the
internal objectives are not obligatory and, because they are not included in the constitutive
instrument of the organization, they can change quickly in response to specific needs.
According to the hierarchy relative to the level of abstraction as a classification
criterion, the objectives may represent the ultimate goal of the organization or, on the
other hand, be intermediate or strategic to achieve the final objective of the organization.
The ultimate goals will be achieved in the long term while the others will be fulfilled in
the short term. Finally, according to their form of articulation, the objectives may be
explicit, implicit and derived from the practice of the organization. The explicit objectives
are included in the constitutive instruments of the organizations while the other two can
be identified in their practice or in instruments derived from the former. By being included
in the constitutive instruments, these enjoy greater legitimacy since they come from the
same States.
Both the classification presented by Shany and that of Perrow show some
problems that do not have so much to do with the identification of the objectives
themselves but with the interpretation made of them. In this sense, some of them may be
stated using terms so broad that it is possible to reach different interpretations (even
contradictory). This affects, on the one hand, the determination of indicators for their
measurement, since it is not clear what is sought to be achieved. On the other hand, the
adoption of strategic or operational objectives, which allow the achievement of the
ultimate objectives, is harmed by the lack of a single and unequivocal interpretation.
Finally, this translates into practical problems such as those related to the allocation of
resources within an organization, since there is no hierarchy and, therefore, no
prioritization in the fulfillment of the objectives because their content is not well defined.
Despite the individuality of each international court, it is possible to state that
there are four generic objectives common to all international jurisdictional organizations,
regardless of the subject matter they regulate. Each of them will be given greater or lesser
weight depending on the specific objectives of the court, which prevents a general study
of them without considering the particularities of each unit of analysis. In the following
pages, each of these objectives is presented in a general manner, and then we focus on the
Revista Facultad de Jurisprudencia No.16
39
case of international human rights courts. Common generic objectives are: support for
international norms; resolution of legal disputes; support for the regime to which a
particular court belongs; and legitimization of public authority. (Shany, 2016, p. 38;
Slaughter, 1994, pp. 114–122)
The first of these is based on the aforementioned densification of the international
normative system. Faced with this proliferation of norms, international actors create
institutions charged with ensuring their compliance. These can be judicial in nature
(international courts) or quasi-jurisdictional in nature (such as the bodies created under
human rights treaties within the UN). Whatever their nature, their objective is to support
compliance with international norms to strengthen, consolidate and, in the long run,
ensure the functioning of the international system.
For Guzmán, through the fulfillment of this generic objective, it will even be
possible to generate what he calls a “de facto international common law,” through a
strengthening of the norms of International Law that the court supervises, interprets and
applies. It is worth clarifying this issue: when it is said that one of the common objectives
of international courts is to ensure compliance with a norm, it should not only be
understood formally but with emphasis on the underlying primary obligation. The
effectiveness of the court, then, for Guzmán, considers its ability to guarantee compliance
with the substantive obligation contained in the primary obligation. (Guzmán, 2008, pp.
174, 178, 188) In terms of human rights, the obligations common to human rights
contained in the American Convention on Human Rights (“ACHR”) are those of respect,
guarantee, non-discrimination and development (or change) of regulatory frameworks (in
addition, the inclusion of the obligation of non-recognition of a situation that violates
human rights was proposed). In view of this, the objective of supporting the international
standard would translate into support for compliance with these obligations, following
the argument correctly raised by Guzmán.
This objective goes hand in hand with that of supporting the regime to which a
particular court belongs. This is because all international courts operate within the
framework of a specific regime. For example, the Court of Justice of the African Union
and the ADHPR Court operate within the framework of the African Union; the European
Mechanisms to measure the effectiveness of International Tribunals
40
Court of First Instance and the European Human Rights Convention (“EHRC”) operate
within the framework of the European Union. As parts of that particular regime, ICT they
must ensure that their objectives are met. (Guzmán, 2008, p. 174; Jodoin, 2010, p. 7;
Shany, 2016, p. 44) Based on this, in the process of measuring the effectiveness of an
international court, it is not only necessary to refer to the objectives set out in its
constitutive instrument, but it is also necessary to make the link with those that the system
considers relevant, in order to establish whether the court helps the system to meet these
objectives.
Another of the generic objectives, the resolution of legal disputes, is framed within
two of the fundamental principles that govern the international relations between States:
the prohibition of the use of force and the peaceful settlement of disputes. This
“disagreement on a point of law or, in fact, an opposition of legal theses or interests
between two” (Case of the Mavrommatis Concessions in Palestine Case, 1925, pp. 11–
12; Guzmán, 2008, p. 174; Novak Talavera & García-Corrochano, 2005, p. 15; Slaughter,
1994, pp. 114–122) or more subjects of international law may be resolved through
diplomatic mechanisms (Novak Talavera & García-Corrochano, 2005, pp. 99–109) or
judicial mechanisms (action of an international court through the determination of the
applicable law). In the case of the determination of the international responsibility of the
State by human rights courts, the situation is no longer conceived in the traditional terms
of “dispute” or “conflict” since the relationship between the intervening parties is of an
asymmetrical nature. This would be verified, for example, in the evidentiary regime
before the IACtHR. (Neira Alegría et al. vs. Peru. Merits, 1995, paras. 65–66; Velásquez
Rodríguez vs. Honduras. Merits, 1988, paras. 135–136) For Shany, individual petitions
and case resolution are support mechanisms for the objective of supporting the validity
of international regulations, making the resolution of disputes an intermediate objective.
(Shany, 2016, pp. 40–42, 107–109) This seems to align with Guzmán’s position
mentioned in previous paragraphs. (Guzmán, 2008)
Finally, the fourth generic objective is to legitimize the public authority that
created a particular court. Courts are expected to provide legitimacy to the actions of the
social and political institutions of the system to which they belong (Shany, 2016, pp. 44–
Revista Facultad de Jurisprudencia No.16
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46). In this sense, the actions of judicial bodies, whether national or international,
contribute to the legitimation of an environment in which they are anchored. It is
important to mention that the legitimation of the system is closely linked to the legitimacy
of the court itself. Thus, if the body is not seen as legitimate, it will not be able to
legitimize the actions of the other institutions that are part of the system to which it
belongs.
THE GOALS OF INTERNATIONAL HUMAN RIGHTS TRIBUNALS: THE
IACTHR
The protection of human rights in the Latin-American region has its milestone in
the approval of the ACHR, but already at the beginning of the 20th century, the Latin
American republics expressed the importance of respect for the rights of individuals in
various international summits.
3
Pan-Americanism, which began at the end of the 19th
century, brought respect for human rights into diplomatic discussion.
4
But it was in
Chapultepec (Mexico), in 1945, during the Inter-American Conference on the Problems
of War and Peace, that it became the prelude to the creation of the OAS. In Resolution
XL, it was the first time that the need to have a system of protection of human rights based
on a conventional instrument on the subject was discussed.
In Petropolis (Brazil), in 1947, the Inter-American Conference for the
Maintenance of Peace and Security in the Continent was held, during which the Inter-
American Treaty of Reciprocal Assistance (TIAR) was signed. And one year later, in
1948, during the IX Inter-American Conference, the OAS was created and the American
Declaration of the Rights and Duties of Man (hereinafter “the DADDH”) was approved.
In the final minutes of said meeting, the possibility of creating a jurisdictional system of
3
About the emergence of the Interamerican HumanRights Protection System, see: (Barbosa Delgado, 2002,
pp. 71–78; Monterisi, 2009, pp. 36–38; Schneider, 2015, pp. 12–16)
4
For example, the First Pan-American Conference, held in Washington in 1889, outlined the principle of
equality and non-discrimination by recognizing that foreigners have the same rights and obligations as
nationals. The Sixth Pan-American Conference (1928) adopted the Havana Convention on Asylum, a topic
that would be taken up again at the Seventh Pan-American Conference in Montevideo. In Lima, during the
Eighth Pan-American Conference in 1938, several resolutions relating to specific human rights and a
declaration on the defense of human rights were approved.
Mechanisms to measure the effectiveness of International Tribunals
42
human rights was discussed. Additionally, the American Treaty on Pacific Solutions
(which reaffirms the principle of peaceful settlement of international disputes), the
International American Charter of Social Guarantees (or Declaration of the Social Rights
of the Worker) and the Inter-American Convention on the Granting of Civil Rights to
Women (in which its only relevant article established that the States Parties committed
themselves to “grant women the same civil rights enjoyed by men”) were approved.
Although the DADDH was not approved as a treaty, in 1954, at the Tenth Inter-
American Conference, held in Venezuela, Resolution XXXIX was approved on the
possibility of creating a court on human rights and the need to have an international
convention on human rights that would complement the DADDH. Within the framework
of this concern for the protection of the person in the region, during the Fifth Meeting of
Consultation of Ministers of Foreign Affairs (1959), the need for a convention on the
subject was reaffirmed and, in Resolution III, the IACtHR was created (whose regulations
were approved in 1960). Likewise, the Inter-American Council of Jurists was entrusted
with developing a study on the relationship between democracy and human rights. In
1965, at the Second Extraordinary Inter-American Conference, held in Brazil, the powers
of the IACtHR were expanded to be able to receive individual petitions of alleged
violations of human rights. And in 1967, through the reform of the OAS Charter, the
IACtHR became a principal organ of the OAS and indicated that an American convention
should determine its structure, competence and operation (Article 150 of the OAS
Charter).
In 1969, during the Specialized Conference on Human Rights, the ACHR was
approved and entered into force in 1978. This instrument embodies more than 30 years
of constant clash between the concern of the States for the protection and promotion of
human rights in the region and their reluctance to cede spaces of their sovereignty to
international entities. For Grossman, the process of creating the SIPDH responds to four
needs: a) the first of these corresponds to the notion that the positive development of
IHRL increases legitimacy beyond national borders; b) in its relationship with democracy,
the SIPDH contributes to avoiding the deterioration and helping to improve democratic
societies with the intervention of an international community interested in the protection
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of human rights; c) these norms and institutions, arising from consensus between States,
do not violate the principle of non-intervention in internal affairs. (Grossman, 1994)
During the first stage of the human rights protection system, it was plagued by
ambiguities. These can be grouped into, on one hand, those that refer to the mechanisms
used to create the system (which, many times, were carried out in response to global and
regional historical events); and, on the other, those related to the functions performed by
its organs. With the entry into force of the ACHR, an attempt was made to bring coherence
to this system by creating a jurisdictional body with powers clearly established in its
constitutive instrument that is binding on the parties.
Once the context in which the SIPDH was created has been analyzed, before
moving on to its specific analysis, it is worth remembering that one of the strengths of the
approach based on the fulfillment of objectives is that its application responds to the
particularities of each of the organizations analyzed. This is because the measurement,
although carried out through a specific methodology, will be based on the objectives
identified for each unit of analysis. In this first stage, the study of the IACtHR is proposed
through a classification based on the hierarchy relative to the level of abstraction, thus
obtaining, on the one hand, ultimate or final objectives and, on the other, support or
intermediate objectives (on the IACtHR, it is possible to review the study by Shany and
Lovat) (Shany, 2016, pp. 253–276). This allows for analysis not only from the perspective
of the mandate providers but also from the court itself, as well as its users. The final
objectives will allow the evaluation of the position of the former, while the intermediate
objectives collect those that the IACtHR itself sets or those that reflect the interests of the
people who use the protection system.
To identify the final objectives, reference will be made to the constitutive
instrument of the IACtHR. These types of objectives tend to be abstract and can suggest
various interpretations. Reference will be made to official documents related to the
IACtHR in which the mandate providers' intentions are expressed in relation to the
identified objectives. For the intermediate ones, the Court's practice will be studied, as
well as pronouncements it has made on the subject.
This paper proposes that the IACtHR will seek to achieve the aforementioned
Mechanisms to measure the effectiveness of International Tribunals
44
generic objectives. The first of these is to support human rights law through the
interpretation and application of the ACHR. This is reflected in article 62(3) of its own
constitutive instrument in the following terms: “[t]he Court has jurisdiction to entertain
any case concerning the interpretation and application of the provisions of this
Convention submitted to it, provided that the States Parties to the case have recognized
or recognize such jurisdiction, either by special declaration, as indicated in the preceding
paragraphs, or by special convention.”
This is also contemplated in Article 1 of the Inter-American Court of Human
Rights (approved by Resolution No. 448 adopted by the OAS General Assembly at its 9th
session in 1979 and amended in 2009). This provision establishes that the Court is “an
autonomous judicial institution whose objective is the application and interpretation of
the American Convention on Human Rights.”
Additionally, the Court fulfills the objective of normative support in a system of
rights protection that is broader than that formed by the ACHR. Thus, the Additional
Protocol to the American Convention on Human Rights (also called the “San Salvador
Protocol”) contemplates, in its Article 19(6), that the system of individual petitions will
be activated for violations of the right to education (Article 13) and trade union rights
(Article 8). This also occurs with the Inter-American Convention on Forced
Disappearance of Persons, which, in its Article XIII, contemplates the possibility that the
Inter-American Court of Human Rights may hear cases in which its violation is alleged.
Regarding the Inter-American Convention on the Prevention, Punishment and
Eradication of Violence against Women (or “Belem do Para Convention”), the Court's
role in normative support is present, not in the exercise of its contentious jurisdiction, but
in its advisory jurisdiction, in accordance with article 11.
In the mentioned treaties, the States themselves, through instruments that make
up the regime of protection of rights additional to the ACHR, have decided that the
objective of the IACtHR is to support respect for international human rights standards.
Despite the clarity regarding this objective, there are cases in which the Court has
exceeded its original jurisdiction, interpreting and applying standards whose supervision
would not be its direct responsibility. This happened with the Inter-American Convention
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to Prevent and Punish Torture. In the Castro Castro Penal case, ratifying its previous
jurisprudence (Gutiérrez Soler v. Colombia, 2005, para. 54; Tibi v. Ecuador. Preliminary
Objections, Merits, Reparations and Costs, 2004, paras. 62, 145, 159), the IACtHR stated
that it
will exercise its material jurisdiction to apply the Inter-American Convention to
Prevent and Punish Torture and determine the responsibility of the State in accordance
with this treaty, ratified by Peru on March 28, 1991, which was in force when the events
occurred. Articles 1, 6 and 8 of the treaty oblige the States Parties to adopt all effective
measures to prevent and punish all acts of torture within the scope of their jurisdiction.
(Miguel Castro Castro Prison v. Peru. Merits, Reparations and Costs, 2006, para. 266)
On the other hand, considering that this is a court anchored to a regime, it is argued
that it also seeks to strengthen it and help it achieve its objectives. Within the framework
of the OAS, respect for human rights has been present since its formation. Already in
1945, at the Inter-American Conference on Problems of War and Peace, in Resolution
XL, the States declared themselves in favor of the existence of a system for the protection
of human rights (Inter-American Conference on Problems of War and Peace, 1945). In
1947, in the Inter-American Treaty of Reciprocal Assistance, the Latin American
republics reaffirmed, in their Preamble, the importance of respect for human rights within
the framework of the democratic system sought in the region. Additionally, in its founding
instrument, the OAS establishes that one of its objectives is “to achieve an order of peace
and justice, to promote their solidarity, to strengthen their collaboration and to defend
their sovereignty, their territorial integrity and their independence” (OAS Charter, 1967).
It continues in Article 3(l), stating that one of its principles is respect for “fundamental
rights of the human person without distinction as to race, nationality, creed or sex” and
that, according to Article 17, the “State shall respect the rights of the human person and
the principles of universal morality.”
In 1959, the Fifth Meeting of Foreign Ministers approved the Santiago
Declaration, which established that harmony among Latin American countries cannot be
a reality without respect for democracy and human rights as one of its fundamental pillars.
(Fifth Meeting of Consultation of Foreign Ministers, 1959) This importance was
Mechanisms to measure the effectiveness of International Tribunals
46
reaffirmed with the approval of the ACHR and the creation of the IACtHR at the
Specialized Conference on Human Rights held in Costa Rica in 1969. The Preamble of
the ACHR establishes that its approval and the creation of the protection regime respond
to the “purpose of consolidating in this continent, within the framework of democratic
institutions, a regime of personal liberty and social justice, founded on respect for the
essential rights of man”, anchored in the concern for respect and the guarantee of human
rights in the American integration system. In this context, the IACtHR is configured as a
jurisdictional body responsible for ensuring compliance with the international obligations
on human rights contained in the ACHR and other instruments in which it is granted
jurisdiction. Likewise, it will help legitimize and support the integration regime in which
it is anchored.
On the other hand, with respect to the objective of resolving disputes, in the case
of international human rights courts, the definition of disputes must be qualified since
there is no equal relationship between two equal entities. In the case of interstate petitions,
one could indeed be configured in the traditional sense, considering which the objective
of resolving disputes will gain importance. However, it is possible to affirm that, in
individual petitions, there is a discussion on points of fact and law that the jurisdictional
body must resolve. Likewise, it is possible to argue that the controversial nature is present
when the ACHR itself provides for the possibility that the IACtHR may make itself
available to the parties (State and IACtHR) to reach a friendly settlement agreement, in
accordance with Article 63 of the IACtHR. In this sense, the Court must achieve the
objective of resolving the disputes submitted to it, recognizing the particularities of
litigation in human rights matters.
This paper proposes that one of the intermediate objectives to achieve the
objective of normative support, support for the system and resolution of disputes is the
reparation of victims. In this sense, although achieving respect and guarantee of human
rights in the region is the final objective of the IACtHR, it is done through reparation of
victims of human rights violations. Cavallaro and Brewer agree on this point (Cavallaro
& Brewer, 2008). This is particularly important, considering the predominance of the
exercise of the Court's contentious jurisdiction (compared to the few advisory opinions it
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has issued to date, in relation to the cases resolved). This reparation is the corollary of the
State's international responsibility, and its modalities will be reflected in the judgment
issued by the Court. Thus, to achieve its final objective, the Court must, in the first
instance, achieve reparation for the victims through the implementation of the measures
it has ordered in each case.
Based on the previous arguments, this research will focus on the study of
compliance with reparation measures understood as an intermediate objective of the
IACtHR that will allow it to achieve its ultimate objective of promoting respect for and
guaranteeing human rights in the region, becoming an effective organization. To this end,
the following section develops the second stage of the methodology proposed by Shany
for measuring the effectiveness of international courts, starting from the definition of
compliance based on the different theories relating to compliance with International Law.
THEORY ON COMPLIANCE WITH INTERNATIONAL JUDGEMENTS.
WHAT IS COMPLIANCE?
As early as 1979, Henkin stated that almost all nations comply with almost all
their international obligations almost all the time. (Henkin, 1979, p. 47) This reading
shows that, despite the proliferation of international agreements, this has not meant full
compliance with them. This point is especially important in those obligations that protect
the person in the international sphere. The commitment to international standards on
human rights does not reach full compliance and, in part, this is because the protection
system is State-centric. On this, Komanovics reaffirms that the main problem is that the
will of the State remains the central axis in International Law. (Komanovics, 2006, pp.
326–327)
Generally, studies on compliance with Public International Law are rooted in the
issue of legality, since the rule of law is based on the idea that everyone must obey the
law. (Huneeus, 2015, p. 440) But this should not be limited to the law formally understood
but must be extended to the rulings of judicial bodies, as a source of law with inter parte
effect. These courts are charged with maintaining peaceful coexistence through the
Mechanisms to measure the effectiveness of International Tribunals
48
resolution of disputes and as mentioned above, the exercise of the right to access justice
does not end with the decision they will deliver but must include compliance with said
ruling by those responsible. (Huneeus, 2015, pp. 444–445)
Compliance with the State's international obligations is understood as the
conformity between the State's conduct and what the law expects of it. However, this
conformity may be the result of several things, even by mere coincidence. In this sense,
Huneeus proposes, contrary to what was proposed by Raustiala and Slaughter (Raustiala
& Slaughter, 2002, p. 539), as well as by Chayes and Handler Chayes (Chayes & Handler
Chayes, 1993), a tripartite definition of compliance: the existence of (a) State conduct
that (b) coincides with what the international norm expects of the State and (c) the
existence of a causal link between (a) and (b) (Huneeus, 2011, pp. 438–443). According
to Huneeus, based on this relational conception, in order to assess compliance with a
reparation measure, it is necessary to carry out a three-stage process: (i) it is necessary to
identify the measure or measures ordered in order to subsequently (ii) assess the State’s
behavior and (iii) compare the result of (i) with the result of (ii) (Huneeus, 2015, pp. 443–
444). These three stages encounter their obstacles in certain factors that seem to influence
compliance with the measures. Thus, for example, the first step may be difficult to
accomplish due to the very design of the reparation measures; and the second may face a
lack of access or lack of rigor in the information on the actions carried out by the State.
Hillebrecht also favors the need for a causal link in his study of compliance with
obligations arising from EHR Court judgments (Hillebrecht, 2009, 2014). Jacoby and
Hawkins agree in pointing out that “when a state persists in a certain behavior long
enough for an international court to rule against that state's practices, and the country
subsequently changes its practices, we assume that the court's ruling helped trigger that
change in behavior, even if other factors may have been important.” (Hawkins & Jacoby,
2010, pp. 39–40)
Jacobson and Brown seem to take a similar position. In their study of compliance
with procedural and substantive obligations, they assess the actions taken by States in
response to the entry into force of environmental treaties. For the authors, such actions
would not exist if the treaty did not impose them on the Parties (Jacobson & Brown Weiss,
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2000), thus confirming the existence of a causal link. Dothan agrees with this, for whom
international courts must ensure that the State complies with its judgments in order to
modify its behavior (Dothan, 2013, p. 458).
Other authors such as Langer and Hansbury do not clearly define what they
understand by compliance but seem to assume a causal relationship between the State’s
conduct and the decision of the IACtHR (Langer & Hansbury, 2012). In his study on the
relationship between the Judiciary and the IACtHR, Huneeus states that compliance with
an international judgment occurs when “a State carries out the actions ordered by a
judgment against it, or refrains from carrying out actions prohibited by said judgment,”
and specifies that compliance can also be understood as implementation (Huneeus, 2011,
pp. 504–505).
Finally, in this research, compliance with a judgment will be understood when “a
State or other party subject to the court carries out the actions required by a court judgment
or refrains from carrying out actions prohibited by said judgment” (Huneeus, 2015, p.
442). In this sense, the causal relationship must be present since the State’s behavior
changes based on the judgment.
Regarding the measurement of said compliance, this is usually dichotomous: the
obligation is fulfilled, or it is not fulfilled. This is verified, for example, in the study
carried out by Hillebrecht on the EHR Court (Hillebrecht, 2014). Staton and Romero
criticize this approach by pointing out that it does not consider other important factors
such as the time it takes the State to comply with the ordered measures. Based on this, the
authors, although they continue to base their study on a dichotomous vision of
compliance, add a variable to their study: resistance (time it takes to implement the
reparation measures). (Romero & Staton, 2011, p. 9) For their part, Jacoby and Hawkins,
in a comparative study between the IACtHR and the ECtHR, propose that it should be a
tripartite study, including partial compliance as one of the most common (Hawkins &
Jacoby, 2010). Huneeus supports this position and suggests that compliance should be
seen as a process that, although it has two extremes (complies/does not comply), allows
for intermediate responses (Huneeus, 2015, p. 444).
Komanovics, in the case of the UN HRC, proposes one of the most comprehensive
Mechanisms to measure the effectiveness of International Tribunals
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measurements using five levels: satisfactory response/action, partially satisfactory,
unsatisfactory, non-cooperation with the Committee, measure contrary to the HRC
recommendations (Komanovics, 2006, p. 334). Similarly, Viljoen and Louw, in their
study of compliance with the decisions of the ADHP Commission, present five categories
for analysis, starting from the conception of compliance as a “dynamic process”: total
compliance; partial compliance; non-compliance; situational compliance; and “unclear
cases”.
The first category consists of compliance with all the ordered measures or an
unequivocal manifestation that it will comply, and the State has taken significant steps to
do so. Non-compliance occurs in the case where the State has not complied with any of
the recommendations of the ADHP Commission. Partial compliance, on the other hand,
requires that the State has complied with some of the reparation measures and the
implementation process continues. Regarding situational compliance, the authors argue
that the dramatic change of government has repercussions on the political will to comply
with the Commission's decisions. Finally, in the “unclear cases”, the information is
insufficient (non-existence of files, difficulties in finding the victims or their
representatives, communication problems, lack of continuity of the State agents involved
in the process before the Commission) and it is not possible to clearly determine whether
and to what extent the reparation measures have been complied with. (Viljoen & Louw,
2007, pp. 5–8)
The model proposed by Jacoby and Hawkins analyzes, based on the above, four
types of partial compliance: divided decisions; state substitution; slow-motion
compliance; and ambiguous compliance in the face of the complexity of the measure.
Regarding the first point, the authors point out (and the data presented in later parts of
this work confirm it) that States, in the checklist model, comply with certain measures
but not with others, and this affects the overall assessment of whether the State complies
with its international obligations in a dichotomous paradigm. Regarding state substitution,
it is proposed that the State replaces one of the measures ordered by the IACtHR with
another of a similar nature but that does not correspond exactly to what was ordered by
the Court. Slow-motion compliance differs from the first category because the State states
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that it will fully comply with a specific measure but in a longer time than expected. As
for the latter, compliance is difficult because the measure itself implies difficult behavior
on the part of the State either because it exceeds its capabilities or because the measure
itself is unclear (what the Court seeks is not clearly defined in the decision). (Hawkins &
Jacoby, 2010, pp. 77–83)
In the regional human rights courts, there are two compliance regimes. (Hawkins
& Jacoby, 2010, p. 43) In the American case, a checklist system is set up in which the
IACtHR orders a series of specific measures that must be complied with by the State, and
will assess, through a report, the total, partial or null compliance of each of them. The
measurement of compliance in the case of the IACtHR is based on the measure ordered
and the information it collects from the State, the victims and their representatives and
the IACtHR. In contrast, in the European system, a delegation regime is established in
which the Court will delegate to the State the assessment of the appropriate reparation
measures, and supervision will be in the hands of a third party not part of the process, i.e.
the Council of Ministers.
IDENTIFICATION OF INDICATORS FOR MEASURING COMPLIANCE
WITH THE JUDGMENTS OF INTERNATIONAL COURTS AS AN
INTERMEDIATE OBJECTIVE
Regarding the effectiveness of ITC, we must identify those indicators necessary
to measure the degree of compliance with the objectives of each tribunal/court. In this
work compliance with the judgments is understood as an intermediate or supporting
objective for the achievement of the final objectives of each court. To measure them, it is
possible to follow Shany's approach, for whom the indicators can be structural, related to
its process, related to its products and related to its results (or outputs). The former refer
to the powers or capacities that the ITC has and that will be used to fulfill its objectives.
The process refers to the way in which its resources are used and how these favors or
impedes the fulfillment of its objectives. As for the products, it is considered that the sum
of the structural and process aspects is what generates products that, in turn, cause results.
Mechanisms to measure the effectiveness of International Tribunals
52
The products, in the case of international courts, correspond to the judgments that they
issue in the resolution of the cases submitted to their knowledge. (Shany, 2016, pp. 49–
61)
There are also other approaches to analyze compliance that are related to this
intermediate objective. In some cases, a merely quantitative study is presented on which
reparation measures are being complied with, without going into depth about the reasons
for these degrees of compliance. This is present even in the monitoring or follow-up
systems of international courts. Similarly, there are other approaches that seek to identify
certain factors that may influence compliance with these measures, without being
exhaustive. (Helfer & Slaughter, 2005, pp. 273–391; Tan, 2005) These, as will be seen in
the following pages, correspond to the indicators that Shany proposes, although they are
not categorized in the same way.
The state of the art shows that there are approaches to compliance with results that
say a lot and little at the same time, mainly because they use of unclear terminology (using
terms such as “acceptable level”, “impressive” rates (Tan, 2005, p. 10), “low rates”
(Baillet, 2013, p. 483), “lack of compliance” (Rodríguez Garavito & Kauffman, 2015, p.
282), “satisfactory” (Komanovics, 2006, p. 340)) without specifying specifically what it
means.
To assess compliance with their own judgments, ITC use their own measurement
models, as mentioned above. However, there is no clear classification methodology, and
the results are unfriendly to users, which prevents these conclusions from being useful
tools to assess compliance with the system's objectives. In the European case, the
supervision of implementation is the responsibility of an independent body of the EHRC:
the Council of Ministers of the Council of Europe. The mechanism used by this body is
equally ambiguous. The results of these analyses are not in a centralized database, and,
with the elimination of the European Commission, the number of cases does not allow
for the permanent updating of this information (it has not been updated since 2006). In
practice, there are three classification parameters: compliance with individual measures
(based on eleven parameters); compliance with general measures; and pending
compliance.
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From the academic point of view, the model proposed by Hillebrecht (Hillebrecht,
2009) is one of the most comprehensive. Although her study is comparative between the
IACtHR and the ECtHR, the author proposes that this model can be used to assess
compliance with any international judgment that includes reparation measures (for
example, the African Court). Her proposal consists of three levels: micro, intermediate
and macro. The micro level is composed, on the one hand of compensation measures
(economic in nature); and, on the other, of individual measures of a non-economic nature.
If there is full payment of the amount set by the court, the value corresponds to 1 or 100%;
if the money has not been disbursed, the value is 0 or 0%. This value (or percentage) will
vary depending on the amount that has been paid. As regards individual non-economic
measures, the assessment is easier in the case of the IACtHR since it specifically
determines which measures the State must comply with (unlike its European counterpart).
The author proposes a two-step study: the first consists of identifying the universe of
measures ordered by the court; and the second, identifying the percentage of compliance
(1 or 100% will be compliance with all measures).
The second or intermediate level is composed of the aggregate of the components
of the micro level (average, if the measures are given equal weight) and the percentage of
compliance with the non-repetition measures ordered. As regards the latter, there is a
difficulty in measuring them since many of them are repeated in various cases that arise
from situations or contexts of systematic violations of human rights. Based on this, the
author proposes that, first, the universe of measures be identified to subsequently
eliminate those that are repeated in the sentences issued by the courts (for example, the
modification of regulations).
Finally, the macro level consists of an aggregate (average) of the results of the
components of the intermediate level. This level can be disaggregated for studies with
material, temporal or global delimitations. One problem that the author herself identifies
is the lack of considerations regarding the time in which the ordered measures are
fulfilled. Furthermore, the limitation of this model is that it does not explain why the State
complies with the ordered reparation measures or what factors influence said compliance.
From reading Hillebrecht's text, the model focuses on the measure itself, from an analysis
Mechanisms to measure the effectiveness of International Tribunals
54
that would seem to aim to go beyond the merely quantitative, but which does not allow
determining those factors that influence compliance with the reparation measures ordered
by ITC.
MODELS BASED ON FACTORS THAT INFLUENCE COMPLIANCE WITH
THE REPARATION MEASURES ORDERED BY ITC
The following paragraphs present the development of a model based on the factors
that influence compliance with the obligations contained in decisions of ITC, seeking the
reasons why certain reparation measures are complied with and others are not. This
proposal is based on the following assumptions. The first is that compliance with the
ordered reparation measures is not unidimensional but is influenced by cultural, social,
political and economic factors. The second is that, despite its preponderance in the levels
of studies on the subject, the analysis of compliance, as mentioned, cannot be
dichotomous. Thus, it is proposed, coinciding with Huneeus, Jacoby and Hawkins, as well
as with the IACtHR itself, that partial compliance is a temporary stage until reaching full
compliance. (Hawkins & Jacoby, 2010, pp. 36–37; Huneeus, 2015)
Another element to consider is that this proposal is based on the consideration that
the existing measurement models do not cover all the factors that influence the
measurement of compliance. In this context, it is proposed that it is possible to divide
them in relation to the court that orders the reparation. Thus, there are two types of factors:
external and institutional. Viljoen and Louw agree when they state that there are certain
factors “inherent to the institutions […] and others that fluctuate from case to case.”
(Viljoen & Louw, 2007, pp. 12, 15–16) External factors can be measured through the
following variables: international pressure on the State; the performance of civil actors;
those elements that are specific to the case; those specific to the State; and those that are
inherent to the court issuing the decision. As for institutional factors, these include: the
nature of the body (taking into account the maturity of the body); the nature of the
decision; the process of determining responsibility (brief reasoning, limited reasoning,
substantial reasoning); the deficit of legitimacy; the lack of political will within the body;
Revista Facultad de Jurisprudencia No.16
55
the existence and nature of a follow-up mechanism; and the procedure (considering the
length of the process and the participation of the State).
Helfer and Slaughter argue, on the other hand, that there are factors under the
control of the States that created ITC (its composition through the constitutive instrument
and the selection process; its capacity to operate; its capacity to carry out an independent
investigation; the nature of the instruments that the court applies). They also identify those
under the control of the ITC (independence and impartiality; expansion of its powers or
incrementalism; quality of reasoning; judicial cross-fertilization and judicial dialogue;
manner in which judges and the court render their opinions); and those that are outside
the control of the States and the ITC (nature of the violations; autonomous national
institutions committed to fulfilling obligations; cultural and political homogeneity of the
States). (Helfer & Slaughter, 1997)
For Shany, some of the structural indicators are present in the proposals mentioned
above. Admitting that they are not the only possible ones, the author mentions the
jurisdictional powers (scope of the jurisdiction of the ITC); the capacity of the staff; the
resources available; structural independence; the potential for use; reputation; and the
relationship with other institutions.(Shany, 2016, pp. 58–59, 99) Contrary to this, we
argue that the “potential for use” does not constitute an independent indicator but goes
hand in hand with the so-called “jurisdictional powers”, since the potential for use
depends on the powers that the mandate providers have granted them. Likewise,
“structural independence” indicator should be unified with the “staff capacity” indicator,
since it is stated that the second is a consequence of the first. It is also considered that the
author leaves aside the power to supervise compliance with the court's decisions
(supervisory power) as a structural indicator that should be considered.
CONCLUSION
This paper uses a relational definition of compliance with obligations arising from
the rulings of international courts. Following Neuman's approach, compliance is
understood as the implementation of the judgement showing a causal link between the
Mechanisms to measure the effectiveness of International Tribunals
56
obligation (reparation of victims) and the conduct of the State (Neuman, 2014, p. 337).
To measure compliance, we proposed to use the goal-based approach since its elements
can be molded to fit the particularities of international human rights courts.
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