Which Dictator Sued Call of Duty? The Real Story Behind Manuel Noriega's Lawsuit

When Real Life Meets Gaming

If you’ve ever played Call of Duty: Black Ops II, you might remember the character based on former Panamanian dictator Manuel Noriega. What many fans don’t know is that Noriega filed a lawsuit against Activision Blizzard in 2014, claiming the game used his likeness without permission. This case made headlines as a rare instance of a real-life political figure suing a video game company.

Why Did Manuel Noriega Sue Call of Duty?

In Call of Duty: Black Ops II, Noriega is portrayed as a corrupt military officer and a key antagonist. Noriega, who ruled Panama from 1983 until his capture by U.S. forces in 1989, claimed that the game's depiction harmed his reputation by labeling him a “kidnapper, murderer, and enemy of the state.”

The lawsuit, filed in California, alleged that:

Activision violated his right of publicity
The game used his image and name for commercial gain
He was portrayed without consent or compensation

Activision’s Response and Legal Defense

Activision quickly pushed back against the claims, arguing the depiction was protected by the First Amendment. The game, they said, was a work of fiction that used Noriega as part of a transformative narrative—something common in movies, TV, and literature.

They even brought in former New York City Mayor Rudy Giuliani to publicly support their case, calling the lawsuit “absurd.”

“This is a clear-cut example of a historical figure being used in a fictional setting,” Giuliani stated. “The First Amendment protects this sort of expression.”

Court Decision: A Win for Creative Freedom

In October 2014, the Los Angeles County Superior Court dismissed Noriega’s lawsuit. The judge ruled that:

Noriega’s depiction was transformative
The character added to the game's creative expression
Video games are protected free speech, just like books or movies

This ruling not only ended the case but also set an important precedent for the use of real-life figures in video games.

What This Means for Gamers and Developers

The outcome of this case was a significant victory for free speech and creative rights in gaming. It affirmed that:

Game developers can use historical figures in fictional contexts
Public figures have limited control over their portrayal in expressive works
Video games enjoy the same legal protections as other art forms

Final Thoughts

Manuel Noriega’s lawsuit against Call of Duty: Black Ops II highlighted a fascinating intersection of law, gaming, and history. While the case may have seemed unusual, it helped establish crucial legal protections for creative storytelling in video games.

So next time you’re playing a mission with a familiar name, remember—it might just be based on a true (and controversial) story.

FAQs

Who was Manuel Noriega in real life?
He was Panama’s military dictator from 1983 to 1989, later convicted of drug trafficking and money laundering.

What Call of Duty game was he in?
Noriega was featured in Call of Duty: Black Ops II (2012).

Did Noriega win the lawsuit?
No. The court dismissed the lawsuit, citing First Amendment protection.

References:

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