Litigation

Leonela Zelaya v. Honduras: Trans Murder Goes Uninvestigated

On January 19, 2026, the Inter-American Court of Human Rights ruled that the State of Honduras is responsible for multiple human rights violations against Leonela Zelaya. The Court ordered Honduras to reopen the investigation, publicly acknowledge responsibility, reform laws to prevent arbitrary detention, and adopt structural measures to address impunity for violence against LGBTI persons.

Leonela Zelaya’s Transfemicide Is Symptomatic of Honduras’ Culture of Impunity Towards LGBTQ+ Murders

In August 2004, Honduran trans woman Leonela Zelaya was arbitrarily detained and held incommunicado for almost 24 hours, during which time she was beaten with batons and gun-butted by police agents in Honduras. Less than one month later, she was found dead, stabbed through the chest. Her body was discovered on a major street in Comayagüela, where it sat overnight before being removed. It took 14 years for Leonela’s case to be investigated.

Born in Cortes, Honduras, Leonela found life as a trans woman exceedingly difficult. Her gender identity, coupled with her career as a sex worker, made her a constant target of violence and discrimination. But Leonela’s story, unfortunately, is not unique. LGBTQ+ individuals in Honduras face one of the most critical situations of increasing human rights violations and insecurity in the Americas, and transgender individuals experience regular transphobia and violent attacks—including from those individuals meant to protect them: state agents.

When Leonela was beaten by police, she was refused medical treatment, despite having visible bruises covering her body and a fever from the beatings. The police failed to collect crucial evidence in Leonela’s case or to identify witnesses. A decade and a half after that inaction, the Honduran state admitted that the investigation file for Leonela’s murder went missing for 14 years.

Why is this a key case?

Police inaction and impunity for perpetrators in transfemicides and other LGBTQ+ cases is rampant in Honduras. Between 2009 and 2019, 312 LGBTQ+ individuals were murdered; only 67 cases were prosecuted. Fewer than one-third of the prosecuted cases ended in a conviction. The rest remain unpunished by the state, with many killings completely uninvestigated.

How is KHRC Supporting Leonela’s Case?

Alongside our Honduran LGBTQ+ partner organization, Red Lésbica Cattrachas, we are working to ensure compliance with the reparations ordered by the Court in its judgment.

Name of the case (as it appears in the respective legal mechanism)

Leonela Zelaya v. Honduras


Month/Year of filing

December 2012 (RFKHR joined as co-counsel in 2015)


Legal mechanism in which the case is being litigated

Inter-American Court on Human Rights


Rights and legal instruments alleged violated (OR found to have been violated)

The Court found that the State violated: 

Articles 1.1  (obligation to respect rights), 3 (right to juridical personality), 5 (right to humane treatment), 7 (right to personal liberty), 8 (right to a fair trial), 9 (freedom from ex post facto laws), 11 (honor and dignity), 13 (freedom of thought and expression), 18 (right to a name), 24 (right to equal protection), 25 (right to judicial protection) of the American Convention on Human Rights.

Article 7 (to live free of violence) of the Inter-American Convention on the Prevention, Punishment and Eradication of Violence Against Women “Belém do Pará Convention”.


Procedural stage

Supervision of compliance with the Judgment.


Counsel

REKHRC and Red Lésbica Cattrachas

Ruling (Spanish)

Summary (Spanish)

Case Partners

  • Red Lésbica Cattrachas

    We partnered to combat gender-based violence and to advance LGBTQ+ rights in Honduras. Our work together includes the 2015 case Leonela Zelaya v. Honduras and, more recently, Vicky Hernandez et al. v. Honduras.

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