On June 8, 1990, the United States District Court for the Southern District of Florida declared with finality that the United States had jurisdiction over General Manuel Antonio Noriega. This decision followed a series of court battles beginning with the indictment issued against Noriega. However, the district court's decision of jurisdiction was subsequently challenged by Noriega on the grounds that the government's taping and the Cable News Network's (CNN) subsequent airing of telephone calls including attorney/ client conversations violated his right to a fair trial. Noriega's motion to dismiss was denied because he failed to prove any injury or any reasonable expectation of confidentiality.
Susan B. Ellington, United States v. Noriega as a Reason for an International Criminal Court, 11 Penn St. Int'l L. Rev. 451 (1993).