Executive Action is a term used by the Central Intelligence Agency starting in the early 1950s to refer to assassination operations. These operations were often conducted by the CIA's Division D, a subsection of the agency's Directorate of Operations. "Executive Action" operations conducted by the CIA ranged from an attempt to kill Fidel Castro using a cigar injected with Botulism toxin to an alleged plan to kill rebel leader Che Guevara. The Ford administration forbade assassination in 1976 with Executive Order 11905. A Washington Post article, c. 1989 , reported that a 'secret' ruling of the U.S. Department of State's Office of Legal Advisor interpreted Ford's Executive Order to ban only intentional killings of foreign leaders, thus clearing the way for 'accidental' killings of foreign leaders -- for example, during the confusion of a coup or invasion. As this ruling was one of at least four preceding the U.S. invasion of Panama, some saw the ruling as giving a green light for Manuel Noriega to be killed 'accidentally.' Noriega survived the invasion and surrendered to US forces.