Manuel Noriega Suing Makers Of ‘Call Of Duty’

Manuel Noriega

Former Panamanian dictator Manuel Noriega is suing the creators of Call Of Duty for using his likeness in their video game:

Manuel Noriega, the former Panamanian dictator, has filed a lawsuit against Activision Blizzard Inc., the video game company behind the popular “Call of Duty: Black Ops II” game, for depicting him as a “kidnapper, murderer and enemy of the state.”

Noriega, 80, filed the lawsuit Tuesday in Los Angeles County Superior Court via his attorney, and is seeking lost profits as well as damages. In the lawsuit, he claims the company included the character “to heighten realism in its game,” which in turn led “directly into heightened sales.”

The game, released in 2012, has a character that bears Noriega’s name and resembles the former Panamanian strongman. The character assists the CIA in capturing a Nicaraguan terrorist but later betrays the agency.

In reality, Noriega’s connections with the CIA go back to the 1950s. He was eventually recruited by the agency and was on their payroll until 1988. But the U.S. grew increasingly concerned with Noriega’s use of violence against his foes and Panamanian citizens during the late 1980s. In 1989, the U.S. invaded Panama, ousted Noriega from power, and imprisoned him in the U.S. on drug trafficking charges.

In the U.S., individuals enjoy the “right to publicity,” which gives them complete control over how their images can be used for commercial purposes. However, it is unclear if that right also extends to Noreiga.

His claim rests on shaky ground since he isn’t a U.S. citizen or resident, an attorney told BBC News, meaning his legal standing to bring the case against the game maker is questionable.

After being deposed, Noriega was tried in the United States and convicted on multiple counts involving drug trafickking, money laundering, and other charges. He was convicted on all charges and sentenced to 30 years in Federal prison, which was later reduced for good behavior. After finishing his sentence in the United States, Noriega was extradited to France to face trial on money laundering charges, of which he was convicted. Upon convicting in France, he was extradited to Panama where he has been serving time in a Panamanian prison on murder and war crimes charges since 2011.

I can’t really comment on the merits of his legal claims here or their chances of success. However, I will say that until I heard this news last night, I had no idea that Manuel Noriega was even still alive.

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Doug Mataconis
About Doug Mataconis
Doug Mataconis held a B.A. in Political Science from Rutgers University and J.D. from George Mason University School of Law. He joined the staff of OTB in May 2010 and contributed a staggering 16,483 posts before his retirement in January 2020. He passed far too young in July 2021.


  1. CSK says:

    I thought he was dead, too.

  2. John Peabody says:

    Dang, a headline name from 1989- when Bush the Elderearsed the ‘wimp factor by invading a country with multiple US bases.

    Oh, if only we had blogs back then!

  3. An interesting case, the first thing I thought was the successful suit brought by former college football players against Electronic Arts for the use of their likeness (but no names) in their NCAA Football series.

    A lot of video games (along with other works of fiction) use the standard “all person fictitious disclaimer” and make up names for the characters.

  4. al-Ameda says:

    Did Speaker Boehner put him up to this?

  5. CSK says:

    I’m interested in the “damages” aspect of this. Does he feel as if his reputation has been hurt? At least one court has ruled that some people’s reputations are already so rancid that nothing anyone says or writes about them is slanderous or libelous. I refer to Leonard “The Quahog” Paradiso.

  6. Franklin says:

    I think a good simple party game would be to quiz guests on a list of formerly famous people as to whether they were currently alive or dead.

  7. gVOR08 says:

    Noriega may be a foreigner, a drug dealer, and a turncoat; but apparently he understands the American Way – sue ’em.

  8. CSK says:


    You could call it “The Dorothy Parker Game,” because when Parker was informed that Calvin Coolidge had died, she reportedly said “How could they tell?”

  9. grumpy realist says:

    Yeah, my brain was throwing up: “Noriega Who? Oh yeah, that guy. Didn’t he die fifteen years ago?”

  10. CB says:

    I remember getting to the part of the game where Noriega shows up and saying out loud, “WTF, they can do that?”. Weird

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