The moment President Donald Trump announced the successful capture of Venezuelan President Nicolas Maduro and his wife from their quarters at a Venezuelan military base, Democrats cried foul, claiming the action was unprecedented and amounted to regime change. The United States has been arresting people on foreign soil since at least 1883, when Frederick Ker was kidnapped by the Pinkerton Detective Agency in Peru and brought back to Chicago to face trial for grand larceny.

The U.S. Supreme Court ultimately endorsed this tactic in Ker v. Illinois. But this was different. Maduro was not merely a foreign national, he was also a head of state. However, Maduro’s arrest parallels an earlier arrest made during the George H.W. Bush administration — the arrest of then-Panamanian dictator Manuel Noriega in 1989. The similarities between the Maduro and Noriega arrests highlight patterns in how the United States has addressed alleged drug trafficking by foreign leaders through military and judicial means.

Here are eight major similarities between the arrests of the two leaders.

Deployment of U.S. Military

Both operations involved U.S. military troops on foreign soil to apprehend the leaders. Noriega was captured during the 1989 U.S. invasion of Panama (Operation Just Cause), where troops surrounded his refuge within the Vatican Embassy. Similarly, Maduro's arrest was carried out by a U.S. special forces raid in Venezuela (Operation Absolute Resolve), leading to his immediate transfer to U.S. custody. The raid itself was conducted primarily by a Delta Force special mission unit, assisted by more than 150 military aircraft.

U.S. Indictments on Drug Trafficking and Related Charges

In both cases, the leaders were indicted by U.S. grand juries prior to their arrests for narcotics-related offenses, including drug trafficking, money laundering, and facilitating large-scale smuggling operations into the United States. Noriega was indicted in 1988 by federal grand juries in both Miami and Tampa, Florida, for drug trafficking, racketeering, money laundering, and related charges. After his capture he was arraigned in Miami, where he was put on trial and found guilty. Maduro was indicted by a federal grand jury in the Southern District of New York under the original charges of narco-terrorism, cocaine importation conspiracy, and related offenses. He was arraigned in the federal courthouse in lower Manhattan.

Determination as National Security Threats

U.S. officials characterized both leaders' activities as threats to the national security of the United States, by combining the criminal narcotics conspiracies with broader issues such as threats to democracy and stability in the region. This justification blurred the lines between law enforcement and military action in both cases.

Disputed Legitimacy and Election Fraud Allegations

The U.S. did not recognize either as the legitimate leader due to claims of election fraud and authoritarian rule. Noriega nullified Panama's 1989 elections, while Maduro's reelections were widely disputed internationally, including by the United States. Therefore, experts argued, neither case amounted to regime change because of their illegitimacy.

Legal Defenses and International Law Debates

Upon arrival in the United States, both leaders pleaded not guilty, described their captures as illegal "kidnappings," and raised defenses involving sovereign immunity, international law violations, and potential prisoner-of-war status under the Geneva Conventions. Noriega's trial set precedents that likely will influence Maduro's proceedings, such as jurisdiction despite forcible capture.

Accusations of Turning Countries into Drug Centers

Both leaders were accused of using their positions to transform their countries into key hubs for international drug networks, profiting personally from cartels and enabling the flow of drugs to the United States.

Buildup of U.S. Military Presence

Prior to both arrests, the United States increased its military footprint in or around the targeted countries, escalating tensions and setting the stage for intervention. Operation Just Cause to capture Noriega was primarily land-based, and was supposed to begin with a gradual buildup of troops in the region. But that buildup was accelerated after members of the Panamanian Defense Force fired upon a group of American servicemen heading to dinner in Panama City, killing one, wounding another. The buildup leading to Maduro’s capture began with a series of airstrikes on 35 known individual drug boats, followed by the deployment of a fleet of U.S. warships in the region.

Both Rulers Abused Human Rights of Citizens

Noriega, who ruled Panama as a de facto dictator from 1983 to 1989, was implicated in numerous human rights abuses against Panamanian citizens, including extrajudicial killings, enforced disappearances, torture, suppression of political opposition, and attacks on civilians. These violations spanned his time in power and earlier roles in the military. Similarly, Maduro’s violations included extrajudicial killings, arbitrary detentions, torture, enforced disappearances, suppression of dissent, and repression of protests and media freedom. The human rights abuses committed by both dictators have been well-documented by the United Nations, Human Rights Watch, Amnesty International, the U.S. State Department, and others.