Justice Department Sought 'Cheap and Easy' Way to Remove Manuel Noriega

By Desmond Okafor · August 16, 2026

US government spent twenty-six years hiding a legal strategy to bypass assassination bans by funding violent coups, with key reasoning still blacked out in official records.

Panamanian citizens spent the 1980s caught between a drug-trafficking military junta and a superpower that viewed their sovereignty as a tactical inconvenience. The cost of this friction was a full-scale invasion that left Panama City scarred and thousands of lives disrupted.

For the architects of American foreign policy, the removal of Manuel Noriega—the military dictator who ruled Panama through puppet presidents—was a logistical problem to be solved. While the public record remembers the 1989 invasion, the archive's curated description of a 1996 internal CIA article suggests there was a more efficient, though more legally precarious, alternative on the table.

"Cheap and Easy"

The article was written by Jonathan Fredman, a CIA lawyer who served during the regime change operation against Noriega. When a redacted version of the piece was released in 2022 via a FOIA request, the government felt it necessary to black out the reasoning behind a specific observation: that after the invasion, many believed the prohibition on assassination had prevented the United States from "availing itself of a cheap and easy way to remove Noriega."

To a lawyer, "cheap and easy" is a matter of efficiency. To a citizen of a target nation, it is a euphemism for a state-sponsored killing. The redactions in the official 2022 release indicate that the government was still uncomfortable with how it had weighed the value of a human life against the cost of a military deployment, even decades after the event.

Document imagery from nsarchive.gwu.edu From the files: nsarchive.gwu.edu

Executive Order 12333

The prohibition mentioned is Executive Order 12333, the directive that forbids the US government from engaging in political assassination. On its face, the order is a firewall against the kind of clandestine murders that characterized the Cold War's darkest chapters. However, the file's catalogue entry records that the Justice Department spent time examining exactly how thin that firewall was.

According to the unredacted text provided by Fredman, the Justice Department prepared a classified legal opinion to determine if supporting a coup against a "repressive regime" would violate the order. The legal gymnastics were precise: the Department asked if the prohibition applied if there were "no specific intent to kill the foreign leader but the plotters contemplated the use of force and the likelihood of violence were great."

In plain terms, the government sought to establish a rule where the US could fund and arm a violent coup, knowing the leader would likely be killed in the process, so long as the US did not explicitly order the hit. It is a distinction that exists only in the imagination of lawyers, not in the blood of the people who die when a city becomes a battlefield.

The Merit of Violence

The Justice Department concluded that Executive Order 12333 "would not necessarily preclude the US from assisting in such a plan." The only caveat was a warning that the legality of any specific proposal would have to be "evaluated on its own merits."

This is the loophole that allows a superpower to maintain a public stance against assassination while privately facilitating the conditions for it. By shifting the focus to the "merits" of the individual case, the government creates a flexible standard where the definition of "repressive regime" can be expanded to fit any leader who ceases to be useful. The logic suggests that as long as the violence is a foreseeable byproduct of a coup rather than a direct order, the US can keep its hands clean while the ground is soaked in red.

Noriega was eventually removed by the weight of thousands of American troops, a move that avoided the legal headaches of a coup but brought the devastation of war to Panama's streets. Other files in the National Archives, including the U.S. v. Noriega legal proceedings and the research files of Mary Beth Riordan Noriega, document the aftermath of that decision. But the Fredman article exposes a colder calculation: the desire for a "cheap" alternative to the invasion.

The official government version of the text remains redacted, leaving the full legal reasoning to exist only on the personal webpage of the lawyer who drafted it.