Gonzales et al. (otton Field v. Mexico, Preliminary Objection, Merits, Reparations, and Costs,

The Cotton Field petition concerned the State's response to the disappearance, torture and murder of three young girls near Ciudad Juarez, Mexico, whose bodies were among eight found in a cotton field. This case is noteworthy for its application of the due diligence standard to assess the State's response to the girls' disappearances. The Court found the murders formed part of a systematic pattern of gender-based human rights abuses in the Ciudad Juarez region, as the murders shared common factors that were indicative of a pattern of violence against women. The Court highlighted that the victims were primarily girl children, a particularly vulnerable group identified in Article 9 of the Convention of Belem do Para. The Court also concluded that the police investigation of the disappearances was inefficient, incompetent and insensitive, and that this failure contributed to a climate of impunity in the Ciudad Juarez region. The Court consequently held that Mexico was in violation of Articles 4(1), 5(1), 5(2) and 7(1) of the American Convention on Human Rights (CADH), namely the rights to life, personal integrity and liberty of the named victims. The Court also found that these rights were violated in connection to Articles 19 and 1(1). However, the Court placed an important limitation on the States obligation of due diligence, noting that a pattern of systemic violence against women does not give rise in and of itself to obligations towards individual victims. It was only once the girls were reported missing by their families that a strict due diligence obligation was triggered.