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In the late 1980s, a winding series of drug trafficking charges against the then de facto leader of Panama, General Manuel Noriega, led the US government to seek his arrest, following a controversial military intervention into Panama, and trial before a US court. The rejection of his entitlement to foreign official immunity by the US District Court for the Southern District of Florida (a verdict affirmed by the Eleventh Circuit Court of Appeals) culminated in an unprecedented decision at the time – long-term imprisonment of the Panamanian strongman in the United States. Not only did the Noriega court pave the way for subsequent prosecutions of top-tier state officials involved in drug trafficking in the United States, but it also brightly reverberated in the scholarly writing of successive decades concerning matters of head-of-state immunity. It also gained international notoriety and was hailed to be a “triumph for diplomacy and a triumph for justice.”
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