San José, Costa Rica, December 11, 2025. In the Judgment notified today, the Inter-American Court of Human Rights declared the State of Brazil internationally responsible in the Case of Leite, Peres Cripsim and Others v. Brazil for the failure to investigate the detention and torture of Denise Peres Cripsim and Eduardo Leite, as well as for the extrajudicial execution of the latter. The Court also declared the State internationally responsible for the violation of the rights to truth and personal integrity due to the impact of the lack of investigation of these events on their families.

The official summary and the full text of the Judgment can be found here .

The events of this case relate to the criminal investigation of what happened between July and December ¹⁹⁷⁰ , during the Brazilian dictatorship, when Denise Peres Crispim, who was six months pregnant, was arrested and accused of committing crimes of subversion and terrorism. Following her arrest, she was taken to the Political-Social Order Police Station (DOPS), where she was interrogated and tortured between July 23 and August 3, 1970. On August 11 of that year, she was taken to a clandestine hospital because the torture was endangering her pregnancy. On October 11, Eduarda, the daughter of Denise Peres Crispim and Eduardo Leite, was born in the hospital where her mother was being held. Her birth was not officially registered at the time.

On August 21, 1970, Eduardo Leite was arrested by DOPS police officers in São Paulo. According to the National Truth Commission (CNV), Eduardo Leite was held in state custody and tortured for 109 days, until December 8, 1970, when the false version of events was disseminated that he had died in an alleged shootout in the city of São Sebastião, São Paulo. The CNV stated that, in reality, he was murdered at the Andradas Barracks in the city of Guarujá, São Paulo, by an Army major.

Regarding the investigation into these events, on July 1, 2011, Denise Peres Crispim reported the kidnapping, torture, and murder of Eduardo Leite to the Federal Public Prosecutor’s Office (MPF). However, the investigation was closed in February 2012 due to the statute of limitations. The investigation into what happened to Eduardo Leite and the detention and torture of Denise was reopened in August 2022 following recommendations from the Inter-American Commission on Human Rights. Nevertheless, in April 2024, the investigation was again ordered closed because the Public Prosecutor’s Office claimed it lacked sufficient evidence to continue the investigation.

In March 1978, Eduarda was registered as “Eduarda Crispim Leite” at the Brazilian Consulate in Rome. The birth certificate listed Denise Peres Crispim as her mother, but, in accordance with Brazilian law, did not authorize the inclusion of Eduardo Leite as her father. Denise Peres Crispim requested the rectification of the birth certificate from the Special Commission on the Politically Disappeared and Dead (CEMDP) in 1996 and from a Civil Court in 2008, but neither request was granted. Subsequently, on May 27, 2009, the Amnesty Commission recognized Denise as a political amnesty recipient and acknowledged her right to include Eduardo Leite’s name on her daughter Eduarda’s birth certificate. Additionally, on November 30, 2009, the 2nd Court of Public Registries accepted the request for rectification of the birth certificate, so on December 11, 2009, Eduardo Leite’s paternity was officially recorded in the birth certificate of Eduarda Crispim Leite.

In this regard, the Court considered that it was not appropriate to declare the State responsible for the alleged violations of Eduarda’s right to identity due to the lack of timely inclusion of her father’s name in her civil birth registration, because that violation was remedied in 2009 when Eduardo Leite was included as the father in his daughter’s civil birth registration, since the State made an apology and paid financial compensation.

In this case, the State made a partial acknowledgment of responsibility for the violation of the right to personal integrity of Denise Peres Crispim and Eduarda Ditta Crispim Leite, protected by article 5.1 of the American Convention in relation to article 1.1 of the same instrument, for the suffering endured as a consequence of the lack of punishment of those responsible for the acts.

In its judgment, the Inter-American Court concluded that the crimes committed against Denise Peres Crispim and Eduardo Leite constituted crimes against humanity. Consequently, it stated that the application of the statute of limitations is prohibited under international law. Furthermore, it emphasized that these acts also constitute serious human rights violations and that the State’s obligation to investigate, prosecute, and, where appropriate, punish these acts remains. In the specific case of what happened to Denise Peres Crispim, the Court emphasized the obligation to conduct the investigation with a gender perspective, given that it involved violence against women.

The Court determined that the State is not responsible for the violation of Article 2 of the American Convention in this case because the Amnesty Law was not applied to the facts of this case. However, it emphasized that the provisions of the Brazilian Amnesty Law should not represent an obstacle to the investigation of the facts of this case, nor to the identification and punishment of those responsible, nor can they have the same or a similar impact with respect to other cases of serious human rights violations enshrined in the American Convention that occurred in Brazil.

On the other hand, the Court acknowledged that, through the Special Commission on the Politically Deceased and Disappeared, the National Truth Commission, and the Amnesty Commission, the State has implemented measures that contribute to fulfilling the right to the truth, both in its individual and collective dimensions. However, given the lack of diligent criminal investigation, the Court considered that the right to the truth has not been fully satisfied in relation to these events.

Additionally, the Court found the State responsible for violating the right to personal integrity of Denise Peres Crispim, Eduarda Ditta Crispim Leite, and Leonardo Ditta, Denise Peres Crispim’s husband, as a consequence of the suffering they endured due to the lack of investigation into these events. With regard to Denise and Eduarda, the Court also recognized the impact on their life plans.

As a consequence of the declared violations, the Court ordered several reparation measures, including: investigating the torture and execution of Eduardo Leite, and the torture of Denise Peres Crispim and, if applicable, prosecuting and eventually punishing the person or persons responsible for these acts, locating the remains of Eduardo Leite and rectifying his death certificate, publishing and disseminating the Judgment and its official summary, holding a public act of recognition of international responsibility, and adopting measures to ensure that the imprescriptibility of crimes against humanity is recognized.