Chapter4 Access to Justice | 109 270. The IACHR notes with deep concern that prisoners at Guantanamo have been, until recently, prevented from litigating any aspect of the conditions of their detention before federal courts, which constitutes per se a violation of one of their most fundamental human rights. The IACHR welcomes the change in recent case law regarding the subject-matter jurisdiction of federal courts to oversee conditions of detention at Guantanamo. As stated in the previous chapter, in order to guarantee that prisoners’ rights are effectively protected in accordance with applicable international human rights standards, the State must ensure that all persons deprived of liberty have access to judicial remedies. 324 271. In its Report on the Human Rights of Persons Deprived of Liberty in the Americas, the IACHR highlighted that “two basic remedies must be available for the protection of the fundamental rights of persons deprived of liberty.”325 On one hand, a remedy to safeguard the right not to be subjected to unlawful or arbitrary detention and, on the other hand, a prompt, suitable and effective remedy to guarantee that conditions of detention do not violate the physical integrity of the detainees. In its Principles and Best Practices on the Protection of Persons Deprived of Liberty in the Americas, the IACHR set standards regarding the nature and scope of those remedies. Principle V provides that “[a]ll persons deprived of liberty shall have the right, exercised by themselves or by others, to present a simple, prompt, and effective recourse before the competent, independent, and impartial authorities […] concerning prison or internment conditions, the lack of appropriate medical or psychological care, and of adequate food.”326 324 325 326 IACHR, Report on the Human Rights of Persons Deprived of Liberty in the Americas, OEA/Ser.L/V/II.Doc.64, December 31, 2011, para 242. IACHR, Report on the Human Rights of Persons Deprived of Liberty in the Americas, OEA/Ser.L/V/II. Doc. 64, December 31, 2011, para. 244. IACHR, Principles and Best Practices on the Protection of Persons Deprived of Liberty in the Americas, Principle V, March, 2008. Inter-American Commission on Human Rights | IACHR