The scene 36 years ago of Panamanian military dictator Manuel Noriega being seized in his own country and extradited to the United States was replayed in South America in 2026. On the 3rd, when U.S. President Donald Trump released the news that Venezuelan President Nicolás Maduro was arrested (local time), the date matched exactly with the day 36 years earlier when Noriega surrendered to U.S. forces and was extradited.
This is the second time since the Noriega case that the United States has secured custody of a sitting leader on foreign soil and brought the person before a U.S. court. Even then, the international community debated whether it was acceptable for a U.S. special operations unit to wield power over the life and death of a sitting head of state on that country's territory.
The United States pushed ahead, fitting Noriega's punishment into its own judicial process. Experts said that, looking at the Noriega case, even if debate over international law surrounding Maduro's arrest grows, the United States is unlikely to halt the trial. Given the America First stance emphasized by the Trump administration, they noted that international criticism and the U.S. judicial process could move in different directions.
◇ Stripping "head of state" immunity and indicting as a "drug criminal"
Noriega was the de facto strongman who ruled Panama in the 1980s. During the Cold War, he cooperated with U.S. intelligence agencies. He mainly served as an intelligence asset assisting operations and information activities in Latin America. Relations soured with the United States as suspicions mounted that he colluded with Colombian drug cartels and used Panama as a drug transshipment route.
At the time, the United States labeled Noriega, the effective head of state, as a drug crime suspect. It was a strategy to avoid a dispute over diplomatic immunity. In 1989, as a legitimacy crisis deepened due to the annulment of Panama's election, the United States designated the Noriega regime as an illegal authority.
Maduro followed a similar path to Noriega. Since taking power in 2013, Maduro claimed victory in the 2018 and 2024 presidential elections. But the international community raised allegations of election fraud against him. Since 2019, his second term in power, the United States has not recognized Maduro as the legitimate president.
The Trump administration indicted Maduro on charges of conspiring in narco-terrorism and even put up a $15 million (about 2 billion won) reward. Experts interpreted this lack of legitimacy as the legal gap that allowed the United States to use military force to capture Maduro.
As with Noriega, the U.S. government applied charges to Maduro as the head of an international drug organization. The U.S. Ministry of Justice viewed Maduro as leading a drug trafficking organization called the "Cartel of the Suns," funneling thousands of tons of cocaine into the United States. According to the indictment released by the U.S. Ministry of Justice in Mar. 2020, Maduro has been accused of using corrupt state institutions as drug smuggling channels over the past 25 years.
While serving as foreign minister between 2006 and 2008, he was known to have sold Venezuelan diplomatic passports to traffickers seeking to launder drug proceeds. The Vienna Convention exempts diplomats and their families from criminal and civil liability in the host country.
Traffickers exploited this privilege to haul cash from Mexico, even using private aircraft. Then-Attorney General William Barr said, "The Maduro regime used cocaine as a weapon aimed at the United States."
◇ "Arrest by operation, punishment in court" U.S. dual track
In Dec. 1989, the United States invaded Panama to seize Noriega. The operation was called "just cause." The United States cited harm to U.S. troops and citizens as the reason for the invasion. As the U.S. military tightened its dragnet, Noriega fled into the Vatican Embassy. U.S. forces blasted rock music around the clock over loudspeakers in a psychological operation. Noriega ultimately failed to last even a month and surrendered on Jan. 3, 1990. He was then immediately extradited to Miami.
The operation to arrest Maduro was more sophisticated than 36 years ago. The Panama invasion was a full-scale war that deployed a large ground force of 26,000 troops. This time, it was closer to a highly technical operation that used precision strikes and special forces to selectively remove only the leadership.
Unlike the nearly three-week operation to capture Noriega, the operation to arrest Maduro in downtown Caracas, the Venezuelan capital, ended in about 30 minutes. Afterward, U.S. forces secured Maduro and his wife and transported them to New York aboard the USS Iwo Jima.
Legal experts predicted that Maduro would follow the exact path Noriega took. Noriega was sentenced in the United States to 40 years for drug trafficking and money laundering. After a reduction, he served 17 years in the United States. He was then extradited to France to stand trial again on grounds that drug money had flowed into French banks and real estate, and he died after moving between prisons in France and Panama.
Maduro likewise faces a path of trials that will continue for years, long-term incarceration, and then political extradition. Maduro is set to be tried in the U.S. District Court for the Southern District of New York on four main charges: conspiracy to commit narco-terrorism, conspiracy to import cocaine, and possession of machine guns and explosives. Hugo Carvajal Barrios, former Director General of Venezuela's Military Counterintelligence (DGCIM), who was indicted on the same charges and is cooperating with the United States, is expected to receive at least 60 years to life. Experts, citing that term, predicted Maduro would also have to spend the rest of his life in prison.
The possibility of being returned to Venezuela is slim. The United States classifies the Maduro regime as a criminal group. It believes Venezuela lacks a reliable judicial system capable of receiving and trying him. Experts said that, like Noriega, Maduro could be extradited to a third country or to a new Venezuelan government only after serving his sentence in the United States, depending on the political situation or whether his sentence is reduced.
The Cato Institute, a U.S. think tank, said, "The courts will approve jurisdiction over Maduro's trial based on the Noriega precedent," adding, "Maduro is highly likely to spend the rest of his life in a federal Supermax prison." Supermax prisons are top-tier correctional facilities that mainly house the most dangerous criminals, such as terrorists, serial killers, and organized crime figures. They have been etched in the public mind as notorious, inescapable prisons, frequently appearing as settings in Hollywood films.
◇ Will Panama-style democratization work in Venezuela?
The U.S. government said it would directly govern Venezuela for the time being. Shortly after Maduro's arrest, President Trump said the United States would run Venezuela "until an appropriate transition is achieved." In the past, the United States quickly achieved democratization in Panama by installing the Guillermo Endara government immediately after Noriega's extradition.
But Venezuela's situation is far more complex than Panama's. In 1990, Panama was a non-oil country with a population of only 2 million. Venezuela is a resource-rich nation with the world's largest proven oil reserves. It is also tightly bound by mutual interests with permanent members of the U.N. Security Council such as Russia and China. Russia and China said after Maduro's abduction that "the United States is destroying the international order by abducting a foreign leader based on its own domestic law."
Some experts in the United States warned that if the legal battle over Maduro's punishment drags on longer than expected, it could spark another international dispute. Citing experts, AP noted, "Maduro's status is far more complicated than Noriega's," and "records that the United States recognized him as president before 2019 could become a variable in the legal fight."
Clark Neily, a researcher at the Cato Institute, said, "If a president uses 'indictment' as a means to conduct military action in a sovereign foreign country, Congress's power to declare war becomes subordinate to presidential discretion," adding, "This is a dangerous sign that the separation of powers system is being distorted into a president-dominant structure."