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[verification needed], reported that a 'secret' ruling of the U.S. Department of State's Office of Legal Advisor interpreted[verification needed] 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[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.