MAGA lawmakers—and the vice president—want you to believe that abducting a foreign leader while he sleeps in his bed is nothing out of the ordinary. They even think they have the perfect precedent, harking back to a previous U.S. invasion of a Latin American country under George H. W. Bush.
The reality is very different.
History does not record exactly what broke General Manuel Noriega’s resolve after he took refuge from American forces inside an embassy in Panama City after a U.S. invasion that began in December 1989.
It could have been Bon Jovi’s “Wanted Dead or Alive” or “I Fought the Law,” by the Clash. Or even Van Halen’s “Panama,” another track that featured on the heavy rock playlist used to flush out the opera-loving Panamanian strongman in a three-day mental torture psyop. Most likely, music fans might say, it was Rick Astley’s “Never Gonna Give You Up.”
Either way, Noriega decided after a 10-day siege that he was going to give himself up to U.S. forces.
It was Jan. 3, 1990, and exactly 36 years to the day before American special forces captured another Latin American strongman, Venezuela’s Nicolás Maduro.
But that’s where the similarities end.
Noriega was not snatched and abducted by Special Forces. He was never the elected head of state in Panama. He was a crooked military leader who ruled through a succession of puppet presidents. The pockmarked former CIA informant had been indicted two years earlier by grand juries in the United States on charges of racketeering, drug-running, and money-laundering.
Even after his capture, after much argument about his legal status as a prisoner of war, it took two years to secure a conviction. Noriega spent the rest of his life in prison in the United States, France, and Panama before his death at 83 in 2017.
Maduro, however, is not just another Latin American warlord. He is the elected president of a U.N. member state, albeit one accused by his compatriots of stealing power and subverting multiple elections. In 2018, much to the anger of the first Trump administration, he even turned up in New York for a defiant speech at the U.N. General Assembly.
The obstacles prosecutors faced in pressing the case against Noriega could prove far greater in a case against an elected head of state with full diplomatic immunity.
The New York Times and CNN were among those to immediately suggest the legal justification for Maduro’s capture may not stand up in court.
Vice President JD Vance began to sketch out the administration’s position by claiming the late-night raid was purely an arrest. “PSA for everyone saying this was ‘illegal,’” he wrote. “You don’t get to avoid justice for drug trafficking in the United States because you live in a palace in Caracas.”
Attorney General Pam Bondi also announced on X that Maduro and his wife have been indicted in the Southern District of New York. She listed “Narco-Terrorism Conspiracy” among the charges. The addition of the word terrorism may be intended to get around the fact that Maduro was not simply captured or arrested, but kidnapped in violation of international law.
Trump inevitably muddied the waters by describing the invasion as a war during a phone call to Fox News.
Reaction to the raid on Venezuela was largely predictable. Russia and a string of allies accused the U.S. of unjustified armed aggression. The EU foreign policy chief urged restraint. Even Nigel Farage, the Trump-allied leader of the U.K.’s Reform Party, suggested that the Americans had violated international law. The U.K. current prime minister distanced himself from the attack.
Closer to home, Rep. Carlos Gimenez, the Cuban-born Republican from South Florida, hailed the Venezuelan raid as “this hemisphere’s equivalent to the Fall of the Berlin Wall” and posted a side-by-side picture of both Noriega and Maduro waving swords at the American imperialists.
“Nicolas Maduro should’ve studied history before waving a sword at President Trump,” he wrote.
“January 3, 1990 we captured Panama’s narcotrafficking dictator Manuel Noriega.
“January 3, 2026 we captured Venezuela’s narcoterrorist dictator Nicolas Maduro.”
Noriega‘s case offers some clues as to how the U.S. may attempt to get around the constitutional and international law issues that this arrest raises, but it offers no clear precedent for Trump. The president has just kicked off another enormous legal fight.
Philippe Naughton has worked as a foreign correspondent around the world for Reuters and as a reporter and foreign desk editor at the Times of London.
