The Inter-american Regional System 3 Under the ACHR, the State will be held responsible for “acts or omissions of any of its powers or organs, irrespective of their rank, which violate the American Convention.” 470 As noted in section 3.1.1, for State responsibility to arise, “it is not necessary to determine, as it is in domestic criminal law, the guilt of the authors or their intention; nor is it necessary to identify individually the agents to whom the acts that violate the human rights embodied in the Convention are attributed.”471 While State responsibility most obviously arises where its agents directly illtreat individuals,472 the mere demonstration of support or tolerance by a public authority of a violation, whether by act or omission, is sufficient to generate State responsibility.473 As the Court stated in Velásquez-Rodriguez v Honduras, “An illegal act which violates human rights and which is initially not directly imputable to a State (for example, because it is the act of a private person or because the person responsible has not been identified) can lead to international responsibility of the State, not because of the act itself, but because of the lack of due diligence to prevent the violation or to respond to it as required by the Convention.”474 To summarise, the act or omission must be in some way attributable to the State and constitute a violation of a previously assumed obligation or one whose source is recognised as customary international law. State responsibility for acts of violence in the private sphere is further extended in the Inter-American Convention to Prevent, Punish and Eradicate Violence against Women (Convention of Belem do Para), Article 1 of which defines violence against women as: “any act or conduct, based on gender, which causes death or physical, sexual or psychological harm or suffering to women, whether in the public or the private sphere.” Pueblo Bello Massacre v Colombia, IACHR (Series C) No. 140, judgement of 31 January 2006, §112. 471 Ibid. 472 See, for example, Mapiripán Massacre v Colombia, IACHR (Series C) No. 134, judgement of 15 September 2005, §112; Moiwana Community v Suriname, IACHR (Series C) No. 124, judgement of 15 June 2005, §211; Tibi v Ecuador (2004), op. cit., §108; Gómez-Paquiyauri Brothers v Peru (2004), op. cit., §91; 19 Tradesmen v Colombia, IACHR (Series C) No. 109, judgement of 5 July 2004, §183; Urrutia v Guatemala (2003), op. cit., § 71; Bulacio v Argentina, IACHR (Series C) No. 100, judgement of 18 September 2003, §111; Sánchez v Honduras, IACHR (Series C) No. 99, judgement of 7 June 2003, §81; Goiburú and Others v Paraguay, IACHR (Series C) No. 153, judgement of 22 September 2006, §66; La Cantuta v Peru, op. cit., §96. 473 Mapiripán Massacre v Colombia (2005), op. cit., §110. See also Servellón-García v Honduras (2006), op. cit., §107. 474 Velásquez-Rodríguez v Honduras (1982), op. cit., §172. 470 102