He 19 January 2026 The Inter-American Court of Human Rights made public the sentence of the case Zelaya vs Honduras. in it, The regional Court declared the international responsibility of the State for multiple human rights violations committed to the detriment of Leonela Zelaya, a trans woman, sex worker and person living with HIV who in 2004 She was illegally and arbitrarily detained on three occasions by state agents and, days later, was murdered.
Although the Court did not declare the State responsible for his death, did consider that his right to personal liberty was violated, your right to equality and non-discrimination, and that there was a lack of due diligence in the investigation of his death, where their right to gender identity and expression was violated.
In addition, The Court recognized Thalía Rodríguez as a victim, trans woman who lived with Leonela Zelaya for nine years and with whom she maintained a family bond. The Court concluded that the investigation was marked by an unjustified delay and by the omission of the duty of enhanced due diligence., which constituted a violation of Thalía's rights to judicial guarantees and judicial protection.
Equally, declared his right to personal integrity violated, as a consequence of the suffering caused by prolonged judicial inactivity and the absence of an effective investigation.
Regarding the illegal and arbitrary detentions of which Leonela Zelaya was a victim, The Inter-American Court determined that they were carried out based on ambiguous regulations that granted an excessive margin of discretion to the authorities., which did not support their actions with objective motivations, but rather they resorted to prejudices derived from their gender identity and their job as a sex worker..
In relation to the criminal investigation that followed his murder, It was concluded that the State incurred serious deficiencies in the investigation of his death, such as the inadequate identification of the victim according to his gender identity and expression., failure to comply with a reasonable deadline and failure to adopt a research hypothesis that would consider the context of violence against trans women in Honduras, the acts of previous violence against them and their gender identity as a possible motive for the crime.
In addition to what has already been mentioned, The ruling develops relevant issues such as the reiteration of the standard set in the case Vicky Hernández vs Honduras regarding the application of the Inter-American Convention to Prevent, Sanction and eradicate violence against women (Belém Do Pará Convention), reiterating that this instrument also protects trans women who are victims of violence based on their gender identity and expression, reiterating the enhanced due diligence standard, which requires incorporating a gender perspective in the investigation and trial of these cases.
The Court also advanced in the protection of families in a broad sense by recognizing that, in cases of violent deaths of trans women, The people who make up the social family of the deceased person may be declared victims for the violation of their rights to mental or moral integrity., provided they prove the existence of a close link with the victim and an impact on their rights, derivative, for instance, of the efforts made to obtain justice.
Among the repair measures, highlights the data collection system that was ordered to be created in the ruling Vicky Hernández vs Honduras, which must also include information on the progress of the processes and the rates of impunity in cases of violence against LGBTIQ+ people.. In addition, The file on the death of Leonela Zelaya must be unarchived and the investigation and eventual punishment of those responsible must be promoted..
The sentence, as a reference in the region, represents a decisive step to protect the life and dignity of trans people in the Americas and the reparation measures ordered strengthen the capacity of the Honduran State to confront structural violence and guarantee justice.
