5th August 2025

Still waiting for justice: What Brisa De Angulo’s case reveals about institutional failures

By Bárbara Jiménez Santiago

5 min read

Bogotá, Colombia, August 2, 2025: Brisa De Angulo waited nearly two decades for a court to acknowledge the sexual violence she experienced as a teenager. Yet she continues to face obstacles in her pursuit of justice. In 2023, the Inter-American Court of Human Rights issued a landmark ruling against Bolivia for failing to prevent, investigate, or prosecute the abuse. The court also found the State had subjected Brisa to cruel, inhuman, and degrading treatment. Despite this historic victory, the systemic failures that denied her justice for so long persist.

This case was the first time the Inter-American Court had addressed incest involving an adolescent survivor, and the Court’s decision set critical legal standards and a regional precedent for the region. Importantly, the judgment highlighted the duty of states to prevent institutional violence and ensure survivors are not retraumatized through legal proceedings.

The ruling reaffirmed that judicial systems must be free from discrimination and practices that re-victimise sexual violence survivors. Equality Now was proud to be part of the legal team that helped secure this historic decision.

Yet Brisa’s aggressor has yet to be held accountable. The accused currently resides in Colombia, and although Bolivia requested his extradition, the Colombian Supreme Court denied it, citing the lack of an identical criminal classification under national law. This decision overlooks international standards that recognise the rights of adolescent survivors of sexual violence are not eroded by time and the obligation to prioritise survivors’ rights under the most favourable applicable norm.

When justice systems retraumatise survivors

Brisa is still waiting for justice, not just for herself but also to ensure that others do not face the same path of impunity and delay.

She reported the abuse in 2002, but the judicial process in Bolivia was marred by serious irregularities, including repeated dismissals of her case, discriminatory treatment, excessive delays, and a lack of protection. Despite multiple legal proceedings over the years, the Bolivian justice system failed to secure a conviction.

Meanwhile, the accused continues to evade justice in Bolivia and has initiated new legal actions against Brisa in Colombia on charges of defamation and slander (injuria y calumnia). As a result, she was called to attend a conciliation hearing with him in Bogotá. This disregards international standards, which clearly establish that no survivor of sexual violence should be required to face the person they have accused in conciliation or mediation proceedings.

This situation reflects a broader institutional failure that retraumatises those who speak out, and it cannot be separated from the systemic dynamics of power, impunity, and gender-based violence.

As both the Committee on the Elimination of Discrimination against Women (CEDAW) and the Inter-American Court have emphasised, States are obligated to ensure that survivors are not subjected to judicial processes that deepen their trauma or function as retaliation. Allowing legal actions to be used to intimidate those who speak out not only violates their rights, it also erodes trust in the very institutions meant to protect them.

What Colombia must do now

We call on the Colombian State to uphold its international obligations by:

  • Ensuring that survivors are not subjected to re-traumatising procedures, particularly when legal mechanisms are used by alleged perpetrators as tools of intimidation.
  • Protecting survivors at every stage of legal proceedings by applying a gender-sensitive approach throughout the justice system.
  • Reassessing the decision to deny the extradition of the accused in Brisa’s case to Bolivia, in light of international human rights standards.

Brisa’s case exemplifies how impunity creates the conditions for ongoing harm. When institutions fail to enforce accountability, survivors may be exposed to prolonged legal and institutional processes that deepen their trauma.

This op ed was originally published by El Desconcierto, in Spanish.

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