On January 5, 2016, the European Court of Human Rights (Court) ruled [3] in Frumkin v. Russia that Russia had violated the European Convention on Human Rights [4] (Convention) by failing to ensure the peaceful conduct of a political rally in Bolotnaya Square and by arresting and detaining of one of the protesters. According to the press release [5], authorities had unexpectedly moved the planned route for the rally, which caused confusion amongst the protesters and eventually led to the termination of the demonstration by the police. Yevgeniy Frumkin, a Russian citizen, was unable to leave the area due to the general commotion and was arrested and “charged with the administrative offence of obstructing the traffic and disobeying lawful police orders.” The Court found that Russia had violated Article 11(freedom of assembly and association) of the Convention because “authorities had not complied with even the minimum requirements in their duty to communicate with the assembly leaders, which had been an essential part of their obligation to ensure the peaceful conduct of the assembly, to prevent disorder and to secure the safety of all the citizens involved.” With regard to Frumkin’s arrest and detention, the Court noted that he “remained within the perimeter of the cordoned meeting venue and that his behaviour remained, by all accounts, strictly peaceful.” It concluded that “the severity of the measures applied against [Frumkin] is entirely devoid of any justification . . . [and] the measures taken against him were grossly disproportionate to the aim pursued.” Finally, the Court stressed “that the arrest, the detention and the ensuing administrative conviction of the applicant could not but have had the effect of discouraging him and others from participating in protest rallies or indeed from engaging actively in opposition politics.”