 Amnesty International claims that corruption continues to undermine access to justice in Brazil, reporting a 2009 corruption investigation in which federal police arrested the president of the Supreme Court of Espírito Santo, along with judges, lawyers and a member of the prosecution service, for alleged involvement in the selling of judicial decisions.The US Department of State reports that the Brazilian legal system is 'complex and overburdened' and that state-level courts are often subject to political and economic influence.Although there are provisions in place to ensure the formal independence of judges, and the broad functional and structural autonomy is guaranteed by the constitution, a 2009 report by Freedom House relates that judicial reform in Brazil has been slower than in other countries in Latin America because the judiciary uses its formal independence to resist change and stop investigations into judicial corruption.