Vienna Convention on Consular Relations (Paraguay v. USA)

On 3 April 1998, Paraguay instituted proceedings against the United States before the International Court of Justice (ICJ) in a dispute concerning alleged violations of the Vienna Convention on Consular Relations (1963). It maintained that Mr. Angel Francisco Breard, a Paraguayan national, was tried and sentenced to death without the State of Virginia advising him of his right to assistance by the consular officers of Paraguay, as required by Article 36 of the Vienna Convention. The Convention came into force in the United States on 24 December 1969.

On 9 April 1998, the ICJ called on the United States to “take all measures at its disposal” to prevent the execution of Mr. Breard, pending a final decision of the Court. Despite this order and a subsequent request from the U.S. Secretary of State to suspend Breard’s sentence, he was executed on 14 April 1998.

Following the execution, Paraguayan officials expressed their resolve to pursue a binding judgment from the International Court of Justice against the United States, as a matter of principle. The United States made an official apology with the guarantee of a better future compliance with the Vienna Convention. On 11 November 1998, the case was removed from the Court’s List at the request of Paraguay.

See also the LaGrand and Avena cases before the ICJ.

Research/ miscellaneous (Research Document)
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