it also involves granting the minimum guarantees of due process to all persons who are subject to its jurisdiction, as established in the Convention. 69. Although Article 8 of the American Convention is entitled “Judicial Guarantees” [in the Spanish version - “Right to a Fair Trial” in the English version], its application is not strictly limited to judicial remedies, “but rather the procedural requirements that should be observed in order to be able to speak of effective and appropriate judicial guarantees”112 so that a person may defend himself adequately in the face of any kind of act of the State that affects his rights. 70. The Court has already established that, although this article does not establish minimum guarantees in matters relating to the determination of rights and obligations of a civil, labor, fiscal or any other nature, the full range of minimum guarantees stipulated in the second paragraph of this article are also applicable in those areas and, therefore, in this type of matter, the individual also has the overall right to the due process applicable in criminal matters.113 71. Although the jurisdictional function belongs, in particular, to the Judiciary under the separation of powers that exists in the rule of law, other public organs or authorities may exercise functions of the same type.114 In other words, when the Convention refers to the right of everyone to be heard by a competent judge or court to “determine his rights,” this expression refers to any public authority, whether administrative, legislative or judicial, which, through its decisions determines individual rights and obligations. For that reason, this Court considers that any State organ that exercises functions of a materially jurisdictional nature has the obligation to adopt decisions that are in consonance with the guarantees of due legal process in the terms of Article 8 of the American Convention. […] 75. This Court considers that, under the rule of law, the independence of all judges and, in particular, that of constitutional judges, must be guaranteed owing to the nature of the matters submitted to their consideration. As the European Court has indicated, the independence of any judge presumes that there is an appropriate appointment process,115 a fixed term in the position,116 and a guarantee against external pressures.117 […] 77. Regarding the exercise of the authority of Congress to conduct impeachment proceedings, which engages the responsibility of a public official, the Court believes that it should be recalled that any person subject to a proceeding of any nature before an organ of the State must be guaranteed that this organ is competent, independent and impartial and that it acts in accordance with the procedure established by law for hearing and deciding the case submitted to it. (Underlining added) 83. The actual members of the ICourtHR have ratified what was stated in the 2001 precedent, which, in my opinion, has great significance today if we consider a continuation in the line of case law on due process under the Convention that the Inter-American Court has been developing since then; so that the rights established in Article 8(2) of the American Convention — in principle addressed at the “minimum guarantees” in criminal proceedings – also extend to the civil, labor, fiscal, or any other order; in other words, the minimum guarantees established in Article 8(2) of the American Convention are applicable to those orders also and, consequently, in that type of matter also there is, “in general,” a Cf. Judicial guarantees in States of Emergency (Arts. 27.2, 25 and 8 American Convention on Human Rights). Advisory Opinion OC-9/87 of October 6, 1987. Series A No. 9, para. 27. 112 113 Cf. Case of Paniagua Morales et al. Judgment of March 8, 1998. Series C No. 37, para. 149. Cf. Eur. Court H.R., Campbell and Fell, judgement of 28 June 1984, Series A no. 80, para. 76, and Eur. Court H.R., case of X v. the United Kingdom, judgement of 5 November 1981, Series A no. 46, para. 53. 114 Cf. Eur. Court H.R., Langborger case, decision of 27 January 1989, Series A no. 155, para. 32, and Eur. Court H.R., Campbell and Fell, supra note 47, para. 78. 115 Cf. Eur. Court H.R., Langborger case, supra note 51, para. 32; Eur. Court H.R., Campbell and Fell, supra note 47, para. 78; and Eur. Court H.R., Le Compte, Van Leuven and De Meyere, judgement of 23 June 198I, Series A no. 43, para. 55. 116 Cf. Eur. Court H.R., Langborger case, supra note 51, para. 32; Eur. Court H.R., Campbell and Fell, supra note 47, para. 78, and Eur. Court H.R., Piersack judgement of I October 1982, Series A no. 53, para. 27. 117 22