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Inter-American Commission Finds U.S. Violated Equality Before the Law in Christa Pike’s Case Ahead of Failed Tennessee Execution

By: Moises Ramirez Gomez
Journal of Global Rights and Organizations, Associate Articles Editor

WASHINGTON, D.C., United States – On September 18, 2026, the Inter-American Commission on Human Rights (“the Commission”) issued a report concluding that the United States is responsible for violating the rights of Tennessee death row prisoner Christa Pike, including her right to equality before the law under the American Declaration of the Rights and Duties of Man. Tennessee attempted to execute her by lethal injection, but the attempt failed. Afterward, the Tennessee Department of Correction stated that it followed every step of the state’s execution protocol, which does not allow for additional procedures.

Execution staff worried IV site might have 'blown' during Christa Pike's  execution attempt | CNN

Christa Pike appears in a Nashville court on April 12, 2012, in an earlier, separate case. 

Pike was sentenced to death after the 1995 killing of Colleen Slemmer, which she committed at age 18. In the year 2020, attorneys from Cornell Law School and the Federal Defender Services of Eastern Tennessee petitioned the Commission and requested precautionary measures, arguing that her trial counsel failed to present mitigating evidence, that she had endured prolonged solitary confinement, and finally, that Tennessee’s execution methods violated her rights. Alongside this, they argued that, as the only woman on Tennessee’s death row, her isolation was a reflection of gender discrimination, because men on death row were housed together.

The Commission found violations of Pike’s rights to life, liberty and personal security, equality before the law, health and well-being, a fair trial, protection from arbitrary arrest, and due process. As a result, it recommended reparation, review and commutation of her sentence, her removal from solitary confinement, and reforms to ensure adequate counsel is given in capital cases. The Commission also noted that the American Declaration does not prohibit the death penalty in itself, but concluded that executing Pike after proceedings that violated her rights would be a serious violation of her rights to life and due process. The United States had objected earlier in the proceeding, telling the Commission in 2020 that Pike had not exhausted domestic remedies and that the jury considered her mental health as a mitigating factor.

Because the United States has signed but not ratified the American Convention on Human Rights, Pike’s case was assessed by the Commission under the Declaration rather than by the Inter-American Court. The Commission first sent its findings to the United States on October 15, 2025. Here, they asked for information on compliance within one month. According to Diplomacy and Law, a legal commentary site, the findings do not change Pike’s Tennessee sentence, nor do they act as a stay in Tennessee courts. Alongside this, the same commentary points that Report 197/26, the Commissions published decision on the Pike’s case, does not say whether Tennessee can attempt a second execution. 

Considering this analysis, whether international law limits a second execution attempt is unresolved. Report 197/26 does not address a repeat attempt, and there is no applicable treaty provision or Inter-American decision it reviewed that bars one outright. On October 1, the UN human rights chief and nine UN experts urged Tennessee not to pursue another attempt. The governor has halted the remaining 2026 executions, and has additionally ordered an independent review. The state says the Tennessee Supreme will decide whether to set a new date. 

In conclusion, Pike’s case leaves two questions open: what effect the Commission’s findings will have in Tennessee, and whether a second lethal injection attempt is permitted. 

For further information, please see:

Diplomacy and Law – Can Tennessee Execute Christa Pike Again? What International Law Says – 7 Oct. 2026

Inter-American Commission on Human Rights – IACHR Publishes Merits Report on Death Penalty and Detention Conditions of Christa Pike In the United States – 24 Sept. 2026 

Inter-American Commission on Human Rights – IACHR Urges the United States to Refrain from Applying the Death Penalty Against Christa Pike, Beneficiary of Precautionary Measures – 18 Sept. 2026

Inter-American Commission on Human Rights – Reports No. 197/26, Case 14.754, Christa Pike – 18 Sept. 2026

Inter-American Commission on Human Rights – Resolution 95/2020, Precautionary Measure No. 1080-20 – 11 Dec. 2020

U.S., Denmark, and Greenland Update 1951 Defense Pact for a New Arctic Era

By: Abigail Wilcher

Journal of Global Rights and Organizations, Senior Article Editor

United States President Donald Trump, Greenland’s Prime Minister Jens-Frederik Nielsen alongside Danish Prime Minister Mette Frederiksen after signing the updated 1951 Defense of Greenland Agreement, courtesy of the White House.

New York, New York – September 22, 2026, the United States of America and the Government of the Kingdom of Denmark together with the Government of Greenland published an agreement amending and supplementing the original April 27, 1951 Defense of Greenland Agreement (“Agreement”). The 1951 Defense of Greenland Agreement is a bilateral treaty signed by the United States and the Kingdom of Denmark on April 27, 1951, under the framework of the North Atlantic Treaty, granting the United States military rights in Greenland during and after the Cold War. The 2026 Agreement preserves that foundational architecture while adapting it to an increasingly contested Arctic, where intensified military activity and strategic competition have elevated regional security concerns.

Under Article IV of the 2026 Agreement, the United States may modernize and expand operations at Pituffik Space Base and establish additional defense areas at Narsaruaq and Mestersvig. Additional installations may be proposed, subject to consultation and mutual agreement among the United States, Denmark, and Greenland (“Parties”). However, if negotiations do not yield agreement within 90 days, the issue must be escalated through successive diplomatic channels. These provisions enable expanded U.S. capabilities while withholding any unilateral authority to create new defense areas absent consensus. Article VI further enhances operational access by authorizing the movement of military aircraft, vessels, and personnel throughout Greenland, including its territorial waters. The Agreement also contemplates expanded defense capabilities associated with the proposed Golden Dome missile defense system. At the same time, all military activities must accord due respect to Greenlandic society, including traditional hunting, fishing, and cultural practices.

Pituffik Space Base pictured in northern Greenland on October 4, 2023, courtesy of Getty Images.

Beyond operational matters, the Agreement incorporates significant national security safeguards. Article IX generally prohibits non-NATO states from establishing military installations or maintaining a persistent military presence in Greenland without the Parties’ agreement. Article X similarly constrainscertain foreign investments involving critical infrastructure, natural resources, and other sensitive sectors where national security or public order may be implicated.

Article XI addresses the Agreement’s durability and Greenland’s constitutional trajectory. It provides that the Agreement has no expiration date and may be amended only by mutual consent. Should Greenland exercise a right to independence, Denmark and Greenland must ensure that the newly independent state remains within NATO and assumes the existing defense obligations. This provision foregrounds complex issues at the intersection of national self-determination and treaty commitments that extend beyond the territory’s present constitutional status.

The amended Agreement updates a Cold War–era framework for a contemporary Arctic security environment defined by strategic competition, heightened maritime and air activity, and the salience of space and cyber domains. By clarifying NATO’s role, codifying access and mobility, and enabling modernization and expansion of Defense Areas, the Agreement positions Greenland as a critical node in allied early warning, space, and North Atlantic defense architectures. For Greenland, provisions emphasizing “maximum respect,” local sourcing preferences, and structured consultation seek to align defense imperatives with societal, environmental, and economic considerations, acknowledging self- governance and the aspiration that benefits flow to local communities. The restrictions on non-NATO military presence and the investment-screening mechanism establish a firmer perimeter against strategic influence via basing or critical-sector investments, reflecting broader transatlantic security-screening trends. Finally, the Agreement’s permanent nature and its independence-contingency clause aim to preserve continuity in defense obligations across potential constitutional outcomes, thereby mitigating uncertainty for long-term basing, interoperability, and allied planning. Ultimately, the amended 1951 Defense of Greenland Agreement modernizes a Cold War defense framework for today’s Arctic, expanding allied flexibility while embedding consultation and economic-security guardrails likely to shape Greenland’s strategic future.

For further information, please see:

The Avalon Project – Defense of Greenland: Agreement Between the United States and the Kingdom of Denmark – 27 April 1951.

The White House – Agreement Between the United States of America and the Government of the Kingdom of Denmark Together with the Government of Greenland – 22 Sept. 2026.

gettyimages – Thule Air Base Stock Photos – 2023.

The White House – United Nations General Assembly 2026 – September 22, 2026 – 2026.

Russia Requests the Netherlands Extradite International Criminal Court President, Tomoko Akane, Among Eight Other ICC Officials

Monica Rodriguez Santana

Impunity Watch Staff Writer 

An exterior view of the International Criminal Court in The Hague, Netherlands, March 31, 2021. Photo Courtesy of Reuters and Piroschka van de Wouw.

THE HAGUE, Netherlands – Russia has requested the Dutch Ministry of Justice and Security to extradite International Criminal Court (ICC) president and Japanese national, Tomoko Akane, among eight other ICC officials. 

The Russian Prosecutor General’s Office announced on October 8, 2026, that it had sent a request to the Dutch government for the extradition of the nine ICC officials following their conviction in absentia in a Moscow City Court in December 2025. The named officials include the court’s current president Tomoko Akane, first vice-president Rosario Salvatore Aitala, second vice-president Reine Alapini-Gansou, and judges Haykel Ben Mahfoudh, Luz del Carmen Ibáñez Carranza, and Sergio Gerardo Ugalde Godínez. The remaining three individuals named no longer sit on the court, including former president Piotr Hofmański, former judge Bartram Schmitt, and former ICC prosecutor Karim Khan. 

The Russian Court found all nine individuals guilty of knowingly bringing an innocent person to face criminal liability, unlawful detention, and an attack on persons enjoying international protection. The named officials received prison sentences ranging from three and a half years to fifteen years. 

This move from Russian authorities comes as retaliation for the ICC’s warrants issued in 2023 against Russian President Vladimir Putin and Maria Alekseyevna Lvova-Belova, the presidential commissioner for children’s rights, for alleged war crimes in Ukraine. The ICC has held them responsible for the unlawful deportation of Ukrainian children from occupied territories to Russia. 

According to the Russian Prosecutor General’s Office, the 2023 warrants issued by ICC officials violated international law and were issued without any evidence. 

Russia has cited its 2016 presidential order withdrawing its intention to become a party to the Rome Statute as the grounds for not recognizing the ICC’s jurisdiction. The Rome Statute is the international treaty that founded the ICC in 2002, to which neither Russia nor the United States are parties. 

This action coincides with the United States’s sanctions on ICC officials, including president Akane, as a result of the U.S. campaign launched in July 2026 to “dismantle the threat posed by the International Criminal Court to U.S. sovereignty.” The ICC authorized an investigation in 2020 into alleged crimes committed by U.S. military personnel in Afghanistan, as well as targeting the U.S. and Israel in its investigation into the conflict in the Gaza Strip. 

This conflict creates a point of contention for Japan as it navigates continued support for the ICC while its closest ally, the United States, works to dismantle the institution. Japanese spokesman Masanao Ozaki stated that the Japanese government plans to “respond appropriately, including by making further representations to Russia” and “maintaining communication with the ICC and other states parties.”

Japan’s Prime Minister Sanae Takaichi, during a recent parliamentary session, stated, “We have consistently supported the ICC in accordance with our efforts to uphold the rule of law, and we will continue to do so.” 

For further information, please see: 

Anadolu Ajansı – Russia seeks extradition of 9 ICC officials convicted in absentia – 9 Oct. 2026

ICC – Rome Statute of the International Criminal Court

Mediazona – Performative mail. Russia requests the extradition of current and former ICC judges sentenced in absentia over the Putin warrant – 8 Oct. 2026

NHK World Japan – Russia requests handover of nine ICC officials – 8 Oct. 2026

The Japan Times – Japan calls Russia’s request to extradite ICC head Akane regrettable – 9 Oct. 2026

ua.news – Russia is demanding that the Netherlands extradite the ICC officials who issued an arrest warrant for Putin – 8 Oct. 2026

Southern States Launch Legal Offensive Against New York, California, and Massachusetts; Lawsuit Seeks to Overturn ‘Shield Laws’ Protecting Reproductive Healthcare Providers 

By Frank Ruscito 

Journal of Global Rights and Organizations, Associate Articles Editor 

On September 30th, 2026, Louisiana, Arkansas, and Alabama filed a lawsuit with the United States Supreme Court to overturn ‘Shield Laws’ enacted in the wake of the Dobbs’ decision. These laws ensure medical professionals practicing in pro-choice states are protected from legal action by state governments that deny patient access to reproductive care. 

Governor Kathy Hochul and pro-choice activists, including Dr. Margaret Carpenter, at the signing of the New York State’s “Shield Law” on December 19th, 2025 (Photo Credit: Center for Reproductive Rights) 

Washington, D.C – The filing, Louisiana; et al. v. New York; et al., asserts that the defendant states are engaged in a scheme to nullify the decision to overturn Roe made in Dobbs v. Jackson Women’s Health Organization by circumnavigating state level abortion bans. They present a legal theory that the defendant states have violated multiple constitutional provisions including the Full Faith and Credit Clause, the Equal-Sovereignty Doctrine, and the Commerce Clause prescription on the interstate transfer of goods, in this case medications banned for purchase or use by state law. 

The rapid closure of reproductive health facilities following Dobbs has led to one in five women in the US reporting that they are geographically isolated from any form of contraceptive care. This collapse in women’s health services is reflected in all three of the plaintiff states, being ranked 46th to 50th in a national ranking of quality of women’s health care. Reproductive rights activists and medical professionals have created inroads into southern states through telehealth prescription services and the mailing of medication intended to empower patients to exercise agency over their right to become or remain pregnant. This has led to a series of lawsuits directed at New York medical personnel by plaintiffs in Texas and Louisiana for civil damages alleging harm from prescribed medications including the case of Dr. Margaret Carpenter, which resulted in a call for extradition by Louisiana Governor Jeff Landry to face criminal charges and potentially up to 15 years in prison for providing prescription medication. As of this writing New York Governor Kathy Hochul has declined to extradite Dr. Carpenter in line with the state’s ‘Shield Framework’ and has described the attempted removal as political theater on behalf of state Republicans in Louisiana. 

With the 2022 Dobbs decision, the United States has been designated as one of four countries to curtail access to abortion following legalization. In a stunning turn Michelle Bachelet, UN High Commissioner on Human Rights, at the time of the decision was forced to comment, claiming that the outcome was a threat to the rights of millions of women, particularly those who are poor or from minority backgrounds. This judicial outcome was championed by the Republican Party and its ideological perspective on the purported immorality of abortion has been extended by the Trump administration’s foreign policy approach. The 2025 reinstatement of the Mexico City Policy or “Global Gag Rule” with regards to family planning services internationally has resulted in the United States being identified as a contributor to the erosion of women’s health resources globally. 

“The Global Gag Rule” predicates funding for women’s health care on ending public support for abortion. It creates a conditional metric that limits international aid organizations from providing complete women’s health care based on their acquiescence to American domestic political prerogatives. This policy as well as other attempts by Trump administration to withdraw from women’s health efforts have imperiled women’s health globally. Almost 11.7 million women and girls across the globe are estimated to have lost access to contraceptive care due to American withdrawals from global sexual and reproductive health efforts.  

The United Nations Gender equality chief has stated that this confluence of new legal barriers on women’s reproductive freedom and influence by political actors in the United States and other nations have weakened the legal position of women worldwide. Based on reports published by the United Nations there has been an observable backslide in women’s rights that began with the current legal regime in the United States. Under the current United States administration’s focus on Republican social prerogatives and historical trends regarding the “The Global Gag Rule” during previous Republican administrations it is likely that American disengagement from global women’s health care will continue and this may lead to a further erosion of women’s reproductive rights in the United States and abroad. 

For further information, please see: 

ABC – Louisiana, Alabama and Arkansas challenge New York’s abortion protections – 30 Sept 2026 

Focus 2030 – State of gender inequality in the world – 2025 edition 

Center for Reproductive Rights – New York’s Strengthened Shield Law Will Further Protect Doctors Prescribing Abortion Medication – 6 Feb 2025 

Center for Reproductive Rights – U.S. Abortion Rights in the Global Context 

Office of Governor Jeff Landry – Governor Jeff Landry Signs Extradition Warrant for New York Doctor -13 Feb 2025 

ABC – Hochul won’t extradite abortion doctor to Louisiana – Feb 13, 2025 

World Metrics – Reproductive Rights Statistics | 2026 Edition 

PubMed Central – The State of International Human Rights Law on Sexual and Reproductive Health: An Overview – 27 Dec 2025 

The Commonwealth Fund – 2024 State Scorecard on Women’s Health and Reproductive Care – 18 July 2024 

The Federal Register – Federal Register :: The Mexico City Policy – 24 Jan 2025 

UN News – Women’s rights are regressing worldwide, warns UN gender equality chief  – 4 March 2026 

Human Rights Group Argues Forced Russian Adoption of Crimean Children Amounts to Enforced Disappearance

By: Carson Roberts

Journal of Global Rights and Organizations, Associate Articles Editor

Strasbourg, France – Ten children, ages one to five at the time, have not been heard from since Russia took control of Crimea in 2014. On September 22, 2026, a Ukrainian human rights group asked the European Court of Human Rights to recognize that silence as an enforced disappearance.

Women with their children in prams walk as armed men, believed to be Russian servicemen, follow them outside an Ukrainian military base in Perevalnoye, near the Crimean city of Simferopol, March 14, 2014. Russia shipped more troops and armour into Crimea on Friday and repeated its threat to invade other parts of Ukraine, showing no sign of listening to Western pleas to back off from the worst confrontation since the Cold War. REUTERS/Vasily Fedosenko (UKRAINE - Tags: POLITICS MILITARY)

Women with children in strollers pass armed men believed to be Russian servicemen outside a Ukrainian military base near Simferopol, Crimea, in March 2014. Photo Courtesy of Vasily Fedosenko/Reuters.

The Ukrainian Helsinki Human Rights Union (UHHRU) filed the application in January 2023 on behalf of the ten children. When Russia asserted jurisdiction over the peninsula in 2014, they were living in state childcare institutions and under the care of the Ukrainian state. According to UHHRU, more than 4,000 children in Crimea without parental care were automatically declared Russian citizens after the occupation began. Ukrainian authorities requested their return. Russia declined and instead opened adoption procedures. Profiles of these ten children later appeared on Russian adoption and foster placement databases, and information about some has since disappeared from public sources. The applicants say this may indicate that the children have been adopted.

The application relies on two provisions of the European Convention on Human Rights: Article 5, which guarantees the right to liberty and security, and Article 8, which protects private and family life. Under international law, enforced disappearance combines deprivation of liberty with a refusal to acknowledge a person’s fate or whereabouts. The applicants argue that the children were unlawfully detained and their whereabouts concealed, constituting an enforced disappearance under Article 5, and that the arbitrary change of their citizenship violated their rights under Article 8.

The Court held the public hearing at the applicants’ request. It will rule on admissibility and the merits later.

Represented by the European Human Rights Advocacy Centre, the applicants argued that the conduct must be read cumulatively. They submitted that imposing Russian citizenship, combined with the ability to change a child’s name, date of birth, and place of birth, erased the children’s social identity as Ukrainians.

Several third parties intervened. International Partnership for Human Rights and the Humanitarian Research Lab at the Yale School of Public Health jointly submitted that the removal, adoption, and Russification of Ukrainian children are not isolated wartime incidents, but amount to “a deliberate state policy,” planned at the highest levels of the Russian government, codified in federal legislation, and administered by permanent federal institutions. The Government of Ukraine and the International Bar Association’s Human Rights Institute also addressed the Court.

The Russian Government filed no observations and did not appear. The judges pressed the parties on the evidence showing that any of the children had in fact left Crimea or been placed with a family, and on why the application was lodged nine years after the events.

The International Criminal Court has charged similar conduct under a different theory. In March 2023, its judges issued arrest warrants for Vladimir Putin and Children’s Rights Commissioner Maria Lvova-Belova for the war crimes of unlawful deportation and transfer of children, covering conduct dating back to at least February 24, 2022. Neither warrant has been executed, and the ICC has no power to make an arrest itself. By contrast, the case before the European Court of Human Rights requires no arrest and reaches back to 2014.

For further information, please see:

Agence Europe – ECHR Holds Hearing on Placement of 10 Ukrainian Children in Russian Adoption System in Crimea – 23 Sept. 2026

Al Jazeera – ECHR Hears How 10 Children Went Missing After Russia Annexed Crimea – 22 Sept. 2026

ECHR – European Convention on Human Rights – 1950

ECHR – Ukrainian Helsinki Human Rights Union on behalf of ten Ukrainian children v. Russia, no. 6719/23 – 10 Jul. 2026

ICC – Situation in Ukraine: ICC Judges Issue Arrest Warrants Against Vladimir Vladimirovich Putin and Maria Alekseyevna Lvova-Belova – 17 Mar. 2023

IPHR – IPHR Addresses European Court of Human Rights on Russia’s Programme of Adoption and Russification of Ukrainian Children – 22 Sept. 2026