Chapter 2 Evolution of the IACHR initiatives on Guantanamo | 29 37. circumstances which include a wide range of measures such as alleged threats, humiliation, sexual abuse, physical and psychological attacks, as well as lack of adequate medical care. The Commission requested the United States to adopt the necessary measures to protect the life and personal integrity of Mr. al-Alwi; to guarantee that the detention conditions are adequate in accordance with applicable international standards; to ensure access to medical care and treatment; and to report on the actions taken to investigate the presumed facts that led to the adoption of this precautionary measure to avoid the repetition of the alleged circumstances. C. Resolutions 38. In keeping with its mandate to monitor the human rights situation in the hemisphere, the Inter-American Commission has published two resolutions regarding the situation of the detainees held at Guantanamo Bay. 39. 40. On July 28, 2006, the Commission issued Resolution No. 2/06 on the Guantanamo Bay Precautionary Measures indicating that the United States’ failure to give effect to the precautionary measures had resulted in irreparable harm to the fundamental rights of the detainees and urging the State, for the first time, to close the detention facility and to remove the detainees through a process that complied with its obligations under international law. 25 The IACHR stated that “over four years after the Commission’s measures were issued, the legal status of the detainees remain[ed] unclear, and it [was] uncertain whether or to what extent independent investigations into allegations of mistreatment at Guantanamo Bay ha[d] been undertaken or what measures ha[d] been taken to ensure that detainees [were] not removed to jurisdictions where they may be subjected to torture or other cruel, inhuman or degrading treatment or punishment.” 26 41. The Inter-American Commission took note of the June 29, 2006, decision of the U.S. Supreme Court in Hamdan v. Rumsfeld in which the Court struck down the military commissions that the United States proposed to use to try the detainees at Guantanamo Bay, based in part upon concerns that the commissions did not satisfy the minimum protections under Common Article 3 to the Geneva Conventions. 25 IACHR, Resolution No. 2/06, On Guantanamo Bay Precautionary Measures, July 28, 2006. Available at: http://www.cidh.oas.org/resolutions/resolution2.06.htm IACHR, Resolution No. 2/06, On Guantanamo Bay Precautionary Measures, July 28, 2006, para. 3. 26 Inter-American Commission on Human Rights | IACHR