Abstract
In 1997 and 1999 respectively, the InterAmerican Court of Human Rights1 and the International Court of Justice2 have been asked to examine art. 36 of the Vienna Convention on Consular Privileges and Immunities3, in the context of proceedings in relation to crimes carrying the death penalty. The first4 found that the Consular Convention concerns the right of due process and the right to life while the second5 concluded that the full effect of the Convention included, according to the circumstances, the right to a remedy in the form of an appeal within the criminal procedure itself. The International Court then issued an order for compliance and non-repetition; no doubt, the Inter-American Court hoped that the United States would at least take its opinion into consideration. However, anyone faintly acquainted with some of United States courts' practice in matter of international law6 could doubt that compliance
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