ABSTRACT
On two occasions, both in the United States, sending states have filed suit against the receiving state and its officials in an effort to prevent the imminent execution of a sending-state national who had not been advised about consular access. Paraguay filed in 1998 against officials of the Commonwealth of Virginia when a Paraguayan national, Angel Breard, faced imminent execution in Virginia. Paraguay filed initially in a U.S. district court. It later filed a separate suit in the Supreme Court of the United States, basing that action on a clause in the United States Constitution that allows the Supreme Court to hear cases affecting ambassadors and consuls. Additionally, the Consul General of Paraguay filed in his own name (Document 2).
