The Death Penalty in the OSCE Area–Background Paper 2021 Observers have remarked that in Virginia international efforts were important for national organizations mostly to boost the morale and reassure them that they had allies. For example, the invitation of activists from Virginia to speak at conferences in Canada reportedly energized and encouraged the movement.117 It was also noted that international involvement in cases such as that of Joseph O’Dell was important in states where governors were Catholic. It demonstrated how international outcry could bolster domestic concern.118 In a different but also important way, governments whose nationals were facing death sentences in the United States also influenced abolition in Virginia by way of their interventions on behalf of their citizens. They initiated consular action, requesting clemency, and bringing amici curiae briefs before the courts, sometimes including the provision of lawyers to represent their nationals. In the case of Breard, for example, the government of Paraguay brought a claim against the United States for violations of consular rights of their citizen before the International Court of Justice who ruled that the United States was required to, “take all measures at its disposal” to stop the execution.119 It was noted that diplomatic interventions of this kind placed death penalty abolition as an issue of international relations rather than a matter of crime and punishment.120 The growing abolitionist international community is also influential in abolition processes through exerting pressure on states more generally. The Parliamentary Assembly of the Council of Europe (PACE) declared that it was becoming increasingly challenging for the Council to accept “observer states which carried out executions” in relation to the United States.121 PACE noted that the application of the death 117 Interview with Mark Warren, op. cit., note 46. 118 “When Joseph O’Dell faced execution in Virginia despite an unresolved claim of innocence, the European response was influential. The Pope and Mother Teresa appealed for clemency as a member from the European Parliament and an official of the Italian consulate flew to Virginia to meet with the state governor. In the days leading up to the execution, nearly ten thousand protesting calls and faxes were logged by the governor’s office, mostly from Italy. The mayor of Palermo made O’Dell an honorary citizen and publicly joined in the crusade to save his life. In contrast, only about a dozen protestors gathered outside of the prison for a candlelight vigil as O’Dell’s last hours approached. After the execution, the city of Palermo chartered a plane to return the body for a public funeral and burial in a cemetery normally reserved for aristocrats and Mafia dons. His tombstone describes O’Dell as “killed by Virginia, U.S.A., in a merciless and brutal justice system,” Mark Warren, “Death, Dissent, and Diplomacy: The U.S. Death Penalty as an Obstacle to Foreign,” William and Mary Bill of Rights Journal, 13(2) (2004), 309–337. 119 Amnesty International, The Execution of Ángel Breard: Apologies Are Not Enough, 1 May 1998, AMR/51/27/98. 120 Interview with Mark Warren, op. cit., note 46. 121 Interview with Mark Warren, op. cit., note 46. 31