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Inter-American Court of Human Rights Holds the State of Honduras Internationally Responsible for Arbitrary Detention and Lack of Due Diligence in the Investigation of the Murder of Leonela Zelaya

[Tegucigalpa/Washington, D.C., January 19, 2026]. The Red Lésbica Cattrachas and the Robert & Ethel Kennedy Human Rights Center, representatives of the victims in the Leonela Zelaya et al. v. Honduras case, welcome the Judgment of the Inter-American Court of Human Rights, notified today, in which the Court declared the international responsibility of the State of Honduras for multiple human rights violations committed against Leonela Zelaya, a trans woman and sex worker, as well as against her social family member, Thalía Rodríguez.

In 2004, Leonela was illegally and arbitrarily detained on multiple occasions by State agents. She was beaten, insulted, and humiliated on the basis of her gender identity and her status as a sex worker. On September 6, 2004, four days after her last detention at the hands of police officers, her body was found lifeless in a public street.

This decision constitutes a long-awaited victory for trans women, for LGBTI persons, and for all victims of structural violence and discrimination in Honduras. The Court recognized that Leonela Zelaya was subjected to illegal and arbitrary detentions, motivated by prejudice and carried out in violation of a regulatory framework incompatible with international human rights standards. The Court further held that the State failed to recognize Leonela’s gender identity and expression during the investigation into her death, thereby reproducing discriminatory practices that deepened impunity.

The Judgment also confirms what civil society has denounced for years: the absence of enhanced due diligence and a gender perspective in the investigation of violence against trans women in Honduras. The Court was unequivocal in identifying the serious deficiencies in the investigation of Leonela Zelaya’s murder, including the incorrect identification of the victim, the loss of the case file for fourteen years, and the failure to pursue lines of investigation linked to the broader context of violence against trans persons.

Importantly, the Court acknowledged the profound suffering endured by Thalía Rodríguez and found violations of her rights to judicial guarantees, judicial protection, and personal integrity, resulting from the unjustified delay and persistent impunity in the case.

The Court recognized that these events occurred within a context of exclusion, violence, and discrimination shaped by gender identity, sex work, poverty, and HIV-related stigma. This context was tolerated and fostered by the Honduran State through the adoption and enforcement of laws and practices aimed at excluding LGBTI persons from the exercise of their fundamental rights. In particular, police forces, acting under the Law on Police and Social Coexistence, criminalized certain conduct and systematically detained and subjected trans women and sex workers to violence.

Within this framework, the Court determined that the arbitrary detentions and violence suffered by Leonela were not isolated incidents, but rather reflected an objective pursued by Honduran laws that enabled institutional violence as a means of punishing those who challenged gender norms and of criminalizing poverty and sex work. The Court further held that, under Inter-American standards, Leonela’s specific situation of vulnerability imposed on the State a heightened duty of protection.

This Judgment reaffirms that gender identity and gender expression are protected under the American Convention on Human Rights, and that violence against trans women constitutes a form of gender-based violence that triggers the obligations established under the Convention of Belém do Pará.

Accordingly, the Inter-American Court found the Honduran State responsible for violations of the rights to juridical personality, personal integrity, personal liberty, the presumption of innocence, the principle of legality, privacy, freedom of expression, name, and equality before the law, under the American Convention and the Convention of Belém do Pará, to the detriment of Leonela Zelaya, as well as for violations of the rights to personal integrity, judicial guarantees, and judicial protection of Thalía Rodríguez.

“For LGBTI people who have survived structural and systemic violence in Honduras, and who have endured violent deaths, extrajudicial executions, arbitrary detentions, torture, discrimination, prejudice, stigmatization, and violence, this Judgment strengthens our determination to continue fighting, because our most meaningful form of reparation is non-repetition,” stated Indyra Mendoza, Director of Red Lésbica Cattrachas.

Regarding reparations, the Inter-American Court ordered the Honduran State to reopen the investigation into Leonela’s murder, to carry out a public act acknowledging international responsibility, to adopt legislative reforms to prevent arbitrary detentions, and to implement structural measures aimed at combating impunity in cases of violence against LGBTI persons.

“This decision comes at a critical moment to advance the long-overdue agenda that the State of Honduras must pursue to transform the conditions of structural violence and discrimination faced by people on the basis of their gender identity and expression, and to guarantee their right to live a full and dignified life,” stated Angelita Baeyens, Vice President for Advocacy and Litigation at the Robert & Ethel Kennedy Human Rights Center. “Moreover, this decision consolidates a roadmap for other countries in the region that face similar contexts of exclusion and prejudice-based violence,” she added.

The representing organizations urge the Honduran State to fully, comprehensively, and promptly comply with the Judgment, and to adopt the measures of reparation and guarantees of non-repetition ordered by the Court to ensure that acts such as those suffered by Leonela Zelaya are never repeated. Leonela’s memory, Thalía’s tireless struggle, and the resistance of LGBTI persons demand truth, justice, and guarantees of non-repetition.We reiterate our commitment to monitor compliance with this Judgment and to continue working toward a region in which LGBTI persons can live free from violence, discrimination, and impunity.

New year, new us. Same mission.

Robert F. Kennedy Human Rights is rebranding to honor the legacy of our founder and hero, Mrs. Ethel Skakel Kennedy. From now on, we will proudly be known as the Robert & Ethel Kennedy Human Rights Center

While our name is changing, our mission and work remain the same. We will continue to fight injustice, advance human rights, and hold governments accountable around the world in 2026 and beyond.