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Ángel Francisco Breard

d: 1998

Ángel Francisco Breard

Summary

Name:

Ángel Francisco Breard

Years Active:

1992

Status:

Executed

Class:

Murderer

Victims:

1

Method:

Stabbing

Death:

April 14, 1998

Nationality:

Paraguay
Ángel Francisco Breard

d: 1998

Ángel Francisco Breard

Summary: Murderer

Name:

Ángel Francisco Breard

Status:

Executed

Victims:

1

Method:

Stabbing

Nationality:

Paraguay

Death:

April 14, 1998

Years Active:

1992

bio

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Ángel Francisco Breard was a Paraguayan national born in 1966. Very little is publicly documented about his childhood or early adult life. At some point in his life, Breard moved to the United States, where he lived in Arlington County, Virginia.

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murder story

In 1992, Ángel Francisco Breard brutally attacked 39-year-old Ruth Dickie, a woman living in Arlington County, Virginia. Breard entered Dickie’s apartment, sexually assaulted her, and fatally stabbed her multiple times. Police quickly identified Breard as a suspect, leading to his arrest the same year.

During his trial in 1993, Breard was convicted of rape and capital murder. The court sentenced him to death. Over the following years, Breard’s case attracted international attention because he was a Paraguayan citizen who was not informed of his right to contact the Paraguayan consulate, a violation of the Vienna Convention on Consular Relations.

Breard’s attorneys filed multiple appeals, arguing that this treaty violation should void his conviction or sentence. In 1998, the case reached the United States Supreme Court in Breard v. Greene (523 U.S. 371), where the Court denied a stay of execution. The Court held that Breard had procedurally defaulted on his Vienna Convention claim by failing to raise it in state court and ruled that the later-enacted federal procedural default rules effectively overrode treaty obligations.

International diplomatic protests, including from Paraguay and the International Court of Justice, were unsuccessful in halting the execution.

On April 14, 1998, Ángel Francisco Breard was executed by lethal injection in Virginia at the age of 32. His case remains significant in U.S. legal history for its impact on international treaty rights and the constitutional principle that domestic statutes can supersede prior treaties.