Leutheusser-Schnarrenberger was also active in the Council of Europe. From 2003 to 2009 she was member of the German delegation at the Parliamentary Assembly of the Council of Europe. As member of the Council of Europe's Committee on Legal Affairs and Human Rights, she conducted an investigative trip to Russia and authored a critical report on the country's judicial system. In 2008, she presented a report to the Parliamentary Assembly on the investigation of the Gongadze case and other crimes of the Kuchma era in Ukraine. Titled Allegations of Politically Motivated Abuses of the Criminal Justice System in Council of Europe Member States, her 2009 report examined alleged abuses in Britain, Germany, France, and Russia. Much of the document focused on Russia, detailing several recent cases that "give rise to concerns that the fight against 'legal nihilism' launched by President Medvedev is still far from won." During an April 2009 visit to Ukraine, Leutheusser-Schnarrenberger, co-rapporteur of the Parliamentary Assembly's Committee on Legal Affairs and Human Rights, cautiously encouraged reform of the parliamentary system in Ukraine. She also expressed regret that those who ordered Georgiy Gongadze's murder had still not been brought to justice.