Head-of-state immunity is one possible defense that toppled Venezuelan leader Nicolás Maduro could use in the federal case against him.

The 1991 trial of Panamanian dictator Manuel Noriega in a Miami federal court on racketeering, money laundering and drug smuggling charges provides the most comparable case in recent U.S. history.

Noriega, who led the country’s military, was fired after his indictment by the elected president. The court rejected Noriega’s immunity argument, because the U.S. did not recognize him as the head of state, according to court records.

By the same measure, the Maduro indictment notes he had “usurped power and was not the legitimate president of Venezuela.”

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