The American Bar Association (ABA) was very troubled to hear of the recent death of Doctor César Barrientos Pellecer on March 2, 2014. We extend our condolences to his family. Dr. Barrientos was a brave defender of the rule of law in Guatemala and throughout Latin America. He will be deeply missed by the legal community. In light of the circumstances of his death, the ABA strongly encourages the government of Guatemala to fully investigate.