
By Gwyneth K. Shaw
Berta Cáceres was a visionary leader and an internationally recognized human rights defender who co-founded the first grassroots organization of Lenca people in Honduras. In 2015, she received the Goldman Environmental Prize for leading a campaign that halted a hydroelectric project from damming a river sacred to Indigenous people that was developed without their free, prior, or informed consent.
After years of harassment and threats, Cáceres was assassinated in her home in 2016.

Nearly a decade later, UC Berkeley Law Professor Roxanna Altholz ’99, director of the school’s Human Rights Clinic, is one of three experts appointed by the Inter-American Commission on Human Rights to conduct an independent and impartial investigation of the killing — a rare mandate granted only three other times in the commission’s history.
“Our task is to uncover who ordered and financed Berta’s murder, to investigate related crimes, and to propose reparations that address not just the harm to Berta’s family, but also to Indigenous communities and social movements that were targeted,” Altholz says. “Berta’s murder sent shockwaves across the world and sent a message to those who defend land, water, and the environment that they are not safe, even in their own homes.”
Unprecedented access
The Interdisciplinary Group of Independent Experts (GIEI) was established in February through an agreement between the Honduran government, the commission, and the Civic Council of Popular and Indigenous Organizations of Honduras and their legal representatives, the Center for Justice and International Law.
Altholz and her colleagues on the panel — Ricardo Aníbal Guzmán Loyo, an experienced criminal prosecutor and a Guatemalan government official, and Argentinian Pedro Martín Biscay, a lawyer and an expert in financial investigations — were originally granted a six-month mandate.
Their task is to go beyond identifying who ordered the crime and confront the ongoing violations that made the murder possible. Even now, the concession granted to the dam project remains in effect, and its parent company still exists. And not only have the banks that financed the project and the perpetrators of the crime not provided reparations, but the Indigenous Lenca communities Cáceres fought to protect still do not hold collective title to their ancestral lands.
“These unresolved issues underscore the need for structural remedies,” Altholz says.
Under the terms of the GIEI agreement, the panel is supposed to have unrestricted access to all the information gathered so far.
“I think that access will allow us to produce a report that is, in and of itself, a meaningful contribution to truth and justice,” Altholz says. “This investigation is innovative. We are engaged in a transnational dialogue that brings together different legal traditions and areas of expertise in service of a profoundly important mission.”
Guzmán says the investigation has been difficult for several reasons: The time elapsed since Cáceres’ murder, the pressures of influential groups, a complex political scenario close to a presidential election, bureaucratic apathy, and “corrupt procedures that permitted a project that exploited natural resources and generated on-going rights violations.”
“Despite the challenges, it has been a unique experience to be part of a multidisciplinary team that integrated seamlessly from the beginning and shared the common objective of achieving justice,” he adds. “Respect for diverse perspectives and appreciation of each member’s expertise have been key to the group’s strong performance, enabling more comprehensive and integrated work.”
The team’s investigation also demonstrates how the struggle for climate justice intersects with violence against human rights and environmental defenders. Caceres’ activism centered on protecting Indigenous territory from destructive development — work that put her on the front lines of the fight against climate change.
“Protecting people like Berta is essential to protecting the planet,” Altholz says. “Rural and Indigenous communities are at the forefront of environmental stewardship, and have been targeted with violence and repression when they resist extractive projects that threaten ecosystems and their way of life.”
Biscay calls working on the Cáceres case “both a profound responsibility and a deeply impactful experience.”
The investigation “requires meticulous analysis of complex evidence, including judicial records, digital data, and witness accounts, to uncover the truth behind a crime that implicated powerful corporate and state actors,” he says. “The case shows the problem of systemic corruption, impunity, and the targeting of activists who challenge environmentally harmful projects, such as the Agua Zarca hydroelectric dam.”

Altholz has visited Honduras multiple times as part of the investigation, along with several clinic students and Clinical Supervising Attorney Helen Kerwin.
“They are getting a unique window into human rights, corporate responsibility, and investigative techniques,” Altholz says. “And Helen is making extraordinary contributions.”
Kerwin says the wide-ranging nature of the case is remarkable, and reflects the diverse political coalitions Cáceres worked with as an activist.
“Within the scope of a single case, the GIEI is taking on criminal investigation and technical assistance to the public prosecutor’s office, and reparations for the harm done that range from securing title to Indigenous lands to addressing how Berta’s murder harmed the movements she worked for,” Kerwin says. “It addresses more broadly the kleptocratic auctioning-off of the Honduran energy market to the benefit of a small elite that created the dam project that ultimately took Berta’s life.”
Working with the GIEI team, she adds, “stretches students’ understanding of how human rights lawyers can intervene in real time to address ongoing injustice, with interlocutors ranging from government ministers to technical staff to the affected communities, to push for justice at the national as well as the international level.”
Creating a template
Cáceres left an enormous legacy. She founded and led a network of more than 200 indigenous communities in Honduras, leveraging that support to create a blockade of the Agua Zarca Dam project that lasted more than a year. In 2015, she won the Goldman Prize, sometimes referred to as the “green Nobel Prize.”
Then her voice was silenced — but in demanding the GIEI process, her family, friends, and supporters laid the groundwork for uncovering real answers about who ordered her assassination. Nine years after the murder, there have been eight convictions, Altholz says, but there’s a strong sense in Honduras that true justice has not been served.
She hopes the team can build a template for real accountability in cases where governmental, financial, and criminal power structures overlap. The work is difficult and dangerous, but worth it, and she’s grateful for the support of the law school — particularly her clinical colleagues and Dean Erwin Chemerinsky — to take it on.
“This investigation presents an opportunity to shift the prevailing approach to killings of human rights defenders in the Americas,” Altholz says. “Too often, state investigations fall short. They fail to earn public trust, focus narrowly on direct perpetrators, and leave the intellectual and financial architects of violence untouched. Our mandate is to challenge that pattern by uncovering the full chain of responsibility.”
Biscay and Guzmán praise Altholz for the expertise, dedication, and leadership she’s brought to the role.
“Working with Professor Roxanna Altholz has been an extraordinary privilege,” Biscay says. “Her ability to navigate intricate legal and political landscapes, combined with her deep commitment to human rights, are instrumental to shaping our report’s findings.”
“Beyond her technical skill, her passion for justice and her ability to mentor students, fostering their investigative and collaborative skills, added immense value to the human rights field.”
Altholz has been a teacher for the group, Guzmán says, sharing her experience in the Central American region through previous exercises in dealing with cases of human rights violations.
“Her human quality, and sense of responsibility toward history, along with her contribution to academic training of future lawyers, make the professor a jewel of knowledge,” he says. “Her commitment, dedication, and enthusiasm are admirable, bringing energy and cohesion to the interdisciplinary group.
“She is a person I wanted to have as a colleague and friend for a long time, in each conversation I learn from her strategic vision.”