The Dictator, Drugs and Diplomacy by Indictment: Head-of-State Immunity in United States v. Noriega
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THE DICTATOR, DRUGS AND DIPLOMACY BY INDICTMENT: HEAD-OF-
STATE IMMUNITY IN UNITED STATES V. NORIEGA
INTRODUCTION
Since his indictment on February 4, 1988,1 General Manuel
Antonio Noriega [Noriega] has been popularly considered a notorious
profiteer in the international narcotics trade and labeled an outlaw
head of state.' Noriega is widely characterized as the de facto head of
Panama, though he has not declared himself as such and is officially
the Commandante of the Panamanian Defense Forces [PDF] . Since
Noriega abrogated the Panamanian presidential elections of May 7,
1989, it has become increasingly clear that he intends to hold onto his
dictatorial power despite the Panamanian people's opposition and the
diplomatic pressures to the contrary exerted by the Organization of
American States [OAS] and the United States. The indictment may
have even strengthened Noriega's resolve.
The Noriega case is unique because it is the first criminal indict-
ment ever prosecuted by the United States against an entrenched dicta-
tor.5 As a military dictator, Noriega is considered by many to be the de
1. United States v. Noriega, 683 F. Supp. 1373 (S.D. Fla. 1988). See infra note 96 and ac-
companying text.
2. Noriega was so characterized both by the United States Attorney's Office and Federal Dis-
trict Court Judge Hoeveler. See infra note 189 and accompanying text.
3. The Panamanian Defense Forces [hereinafter PDF] were a creation of Noriega whereby he
combined the National Guard, other Panamanian military and police forces, canal matters, and
many other important bureaucratic departments (immigration, passports, civil aviation) all under
the PDF. Bruck, How Noriega Got Caught and Got Away, 10 AM. LAw. 34, 36 (1988).
4. See Pear, Latin Envoys Report No Progress In Their Effort to Dislodge Noriega, N.Y.
Times, June 20, 1989, at A8, col. 1; Eisenmann, How to Block Narco-Militarism in Panama,
Hartford Courant, June 29, 1989, at B9, col. I (Eisenmann is the editor of the Panamanian
newspaper, La Prensa, which has been closed and occupied by the PDF).
5. There have been criminal cases involving former dictators. See, e.g., Jimenez v. Aris-](ViewImageLocal?handle=hein.journals/conjil4&div=48&collection=&method=preview&ext=.png&size=3)
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The Dictator, Drugs and Diplomacy by Indictment: Head-of-State Immunity in United States v. Noriega
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