The Plan de Sánchez massacre took place in the Guatemalan village of Plan de Sánchez, Baja Verapaz department, on 18 July 1982. Over 250 people (mostly women and children, and almost exclusively ethnic Achi Maya) were abused and murdered by members of the armed forces and their paramilitary allies. The killings took place during one of the most violent phases of Guatemala's Civil War, which pitted various groups of left-wing insurgents against the government and the armed forces. After assuming power in March 1982, de facto President Gen. Efraín Ríos Montt embarked on a military campaign that largely succeeded in breaking the insurgency, but at a terrible cost in human lives and human rights violations. The massacre in Plan de Sánchez was an element in the government's scorched earth strategy, and the village was targeted because of the authorities' suspicions that the inhabitants were harbouring or otherwise supporting guerrilla groups. After the massacre, the village was practically abandoned for a number of years, and the survivors were told that reprisals would follow if they spoke about the incident or revealed the location of the numerous mass graves they had helped to dig. With the gradual return to democracy that began in the late 1980s and early 1990s, some of the survivors felt they could start to talk about the killings without fearing for their lives. Accusations were filed with the authorities in 1992 and, in 1993, a criminal investigation was launched. However, faced with delays and other irregularities in the proceedings, and stonewalled by a National Reconciliation Law that granted amnesties to the suspected perpetrators, the survivors saw that Guatemala's domestic legal remedies were ineffective in this case. They consequently decided to lodge a complaint with the Inter-American Commission on Human Rights (IACHR), the supranational human rights arm of the Organisation of American States, in 1996. The IACHR began processing the complaint, received a partial recognition of the state's institutional responsibility from the democratically elected president Alfonso Portillo in the first year of his term, and finally referred the case to the Inter-American Court of Human Rights for judgement and settlement. In 2004, the Inter-American Court issued two judgements, in which it established Guatemala's liability in the case and ordered an extensive package of monetary, non-monetary and symbolic forms of compensation for the survivors and the next-of-kin of the deceased. National context 1982 was one of the bloodiest years in