Easily. There are numerous cases, including very recent cases of that being so. One of our key recommendations to the Colombian government--and this goes back years--is the absolutely vital importance that the government stop deriding the work of human rights defenders, who are so vital to moving forward a meaningful human rights agenda in Colombia, but constantly have their work derided in these ways that accuses them of being supporters or even direct members of guerrilla groups simply because they're speaking out about social justice issues. That has then traditionally been taken as an implicit signal to paramilitary groups that those individuals should be treated as valid targets.
On April 30th, 2008. See this statement in context.