The Ford administration forbade assassination in 1976 with Executive Order 11905. A "Washington Post" article, c. 1989 may have reported that a "secret" ruling of the U.S. Department of State's Office of Legal Advisor had interpreted that Ford's Executive Order only banned "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. Since this ruling was one of at least four preceding the U.S. invasion of Panama, some who saw the ruling as giving a green light for Manuel Noriega to be killed "accidentally". Noriega survived the invasion and surrendered to US forces.