Loyola of Los Angeles International and

DaCosta Cadogan guilty of murder and sentenced him to death by hanging; a sentence that is in accordance with Barbados’s Offences Against the Persons Act of 1994. Barbados imposed this mandatory death penalty sentence without considering the specific circumstances of the crime or the mitigating factors. As a consequence of a savings clause in the Constitution of Barbados, the domestic courts could not declare the mandatory death sentence to be invalid even though it violated fundamental rights protected under Barbados’s Constitution and the American Convention on Human Rights. I. FACT