Executive Authority and the Contras
The following is a reproduction of an essay that I wrote for one of my modules at King’s College London:
To what extent was the United States’ participation in the contra affair enabled by the expansion of presidential powers under the Reagan administration?
Introduction
The President of the United States (POTUS) is variously characterized as the leader of the free world, the most powerful individual on earth, or as the mouthpiece of the world’s last superpower. The executive branch of the U.S. federal government has undergone extensive changes since its inception in 1789. In the wake of a tumultuous transition of power following the Trump presidency, it is easy to forget the institutional transformations meted out over the last 150 years of peaceful regime change that enabled his ascent. Tracing the arc of executive authority through the 20th century, some analyses begin with Franklin Delano Roosevelt, while others focus on Richard Nixon. Both presidencies established key precedents in the limits of congressional oversight of the highest elected office in U.S. politics, but the Ronald Reagan administration took full advantage of the ambiguity in constitutional interpretation, famously evading impeachment and any post-presidency consequences for the Iran-Contra scandal in 1986.
This essay will evaluate the relationship between the expansion of presidential powers in the U.S. and its participation in the Nicaraguan Contra War, examining the legal mechanisms that failed to constrain the intelligence community’s activities under the Reagan administration. The structure of this essay will follow the development of executive branch intelligence agencies from the Truman administration to Iran Contra, then assess the Contra Affair itself, and finally there will be an analysis of the collapse of congressional oversight. The judiciary branch’s lax posture towards the president’s foreign policy apparatus seriously impacted the legislative branch’s ability to constrain war powers and national security activities, and I will argue that this breakdown is the critical factor in moulding the U.S.’s conduct abroad. Crucially, this lapse in jurisprudence allowed the Reagan administration to ignore the Boland Amendments, which officially put military or financial assistance to the Nicaraguan Contras in tension with the law.
As this precedent relates to the Reagan administration, the devout anti-communist was surrounded by conservative hardliners who were poised to take advantage of this obeisant judicial disposition in Latin America. In a top secret White House communiqué (National Security Decision Directive 17: On Cuba and Central America) from January 4th, 1982, Reagan laid out the broad strokes of his Latin American policy and set priorities for the intelligence community, including two key provisions for Nicaragua. First, NSDD17 authorized the Central Intelligence Agency (CIA) and the National Security Council (NSC) to “provide military training for indigenous units and leaders both in and out of country.” Second, it pledged explicit support for “democratic forces in Nicaragua.” This document would be the foundational legal dispatch for the hostile intelligence activities conducted throughout the 1980s, most notably the triangular arms trade between the U.S., Iran, and Nicaragua. The historical relationship between the U.S. and the Americas has been one of paternalistic intervention from North America, and reactionary violence against Central and South American attempts to establish their own distinct political ideologies. The Reagan administration further entrenched this arrangement, and endowed future White House occupants with new tools for its future maintenance.
The Co-evolution of the Executive Branch and the Intelligence Community
The CIA and the NSC were established by the National Security Act of July 26, 1947. Although the Truman administration did not initially envision the two agencies to be direct extensions of the executive office, they quickly became subsumed into it. The NSC morphed into “a virtual adjunct of the presidency” after Dwight D. Eisenhower consolidated its staff with that of the White House in the 1950s, blurring the lines between U.S. government bureaucratic organizations and the presidency itself. Similarly, the CIA’s relationship with the presidency grew closer under Eisenhower, however the agency was still officially bound by congress at this point. Towards the end of the Eisenhower presidency, the President ordered an evaluation of the CIA’s conduct to determine whether it “had strayed from its primary mission of intelligence gathering” since its inception. In 1961, CIA director Allen Dulles delivered a report confirming that the majority of the CIA’s funding was instead diverted towards “covert action,” and “regime change” in developing countries that had established communist rule. This trend of mission creep concerned Eisenhower, but it arrived too late in his second term to effectively respond. After the 1960 election, President-elect John F. Kennedy was ready to double down.
Under Kennedy, the NSC’s original mission as a foreign policy planning body was essentially rendered obsolete and subservient to its operational capacity. In particular, the Bay of Pigs incident provided Kennedy with the key justification to expand the NSC’s responsibilities, following what Kennedy called a necessity in streamlining diplomatic functions in times of crisis. As a result, the NSC could undertake duties formerly reserved for the U.S. Department of State, which was subject to congressional oversight and was limited by certain pre-defined administrative process such as document preservation.
Kennedy’s CIA was often the driving force behind the 35th President’s foreign policy decision-making process. Kennedy would go on to encourage CIA leadership to explore possible avenues of covert action against Fidel Castro and other ascendant leftists in Latin America, and his leadership would lay the groundwork for the high level of autonomy afforded to the intelligence community in future administrations. Pursuant to promises made on the campaign trail during the 1960 election, Castro’s elimination became a big-ticket item on Kennedy’s agenda and although this goal would never be realized, the failed project would permanently endow the CIA with presidential authority. After the failure of the CIA-lead Bay of Pigs invasion, Kennedy ousted high ranking CIA leadership figures and attempted to move his brother from Attorney General of the Department of Justice to Director of the CIA, but the president was advised by his legal counsel that doing so would undermine Kennedy’s plausible deniability over CIA operations. This principle stands on dubious legal grounds outside the ironclad context of criminal defence law, but its value in future administrations, including the Reagan administration, would only grow.
As the intelligence community grew in importance for the conduct of U.S. government business abroad, so to did its interchangeability with the Executive Branch itself. During the Reagan years, the NSC was further incorporated within the White House, and its personnel were made answerable to National Security Advisor Robert MacFarlane. In turn, this manoeuvre had the effect of transferring power from the State Department into the Executive Branch, because the President’s staff were now capable of internally handling key intelligence briefings and information provenances that were previously sourced from outside the executive.
By the end of Reagan’s presidency, the activities of congressionally regulated governmental agencies such as the Drug Enforcement Administration and the State Department would regularly conflict with the clandestine pursuits of unaccountable bodies like the CIA and the NSC. As long-standing institutions like the traditional Presidential cabinet waned in importance, the indispensability of newly established alternatives waxed. The consequences of this reconfiguration were widespread, and U.S. foreign policy seemed disjointed and hard to articulate as a result.
In 1981, President Reagan signed Executive Order 12333. This order forms the basis of the domestic surveillance apparatus of the contemporary U.S. intelligence community, but at the time of its introduction it was aimed at foreign targets. Specifically, it eliminated the need for government agencies to obtain warrants from the Judiciary and rendered the inherent power of any executive dispatch functionally identical to court approval. This investment in the intelligence community further built upon the legacy of Kennedy and Eisenhower by making the connection between executive authority and the legitimacy of its actions explicit.
In essence, the Reagan administration came into power after a period of overhaul for the Executive Branch that lasted over 40 years, and its actions post-inauguration went to great lengths to harness and refine the improvements made by its predecessors. The absorption of the NSC into the White House’s staff gave it new powers of public diplomacy and a much deeper independent operational capacity. The expansion of the CIA’s mission and autonomy would disconnect it from critical oversight mechanisms, even at the expense of the President’s own agenda. In total, these modifications made the Reagan Presidency a watershed moment in U.S. government.
The Contra Affair
As the Iran-Iraq War of 1980 grew in intensity, a small contingent within the U.S. intelligence community (most notably Robert MacFarlane) saw the decision to support Iraq as folly and thought that prolonging the conflict could spill over into a favourable regime change in Iran. Officially, Congress and the President had disbursed funds for arms and aid to the Iraqi camp, but the CIA and NSC “began pursuing both conflicting [Middle Eastern] policies” that undermined the strategic interests of the U.S. This prelude to the Iran Contra scandal exemplifies the problem inherent of the bloated executive, as ill-governed bureaucracies were allowed to repeatedly contradict both Congress and the Secretary of State.
By 1982, MacFarlane’s faction in the White House had established the bare bones of what would blossom into the first leg of the triangular arms trade by 1985. Keen to re-establish diplomatic relations with Iran, the NSC cohort sought to prevent an enduring victory from being achieved by either side in hopes that Ayatollah Khomeini’s young regime would seek Western alignment to secure his own position. According to a special prosecution report during the Clinton administration, both NSC and CIA personnel sought to establish points of contact within the Ayatollah’s regime between 1983 and 1986 to secure the release of U.S. nationals held in Lebanon in exchange for arms. Although the hostage release component of the deal was not fully realized, the U.S. did send a litany of weapons platforms to Iran during this period.
The second leg of the Contra affair began under legitimate auspices, and with limited support from Congress. Reagan entered office on campaign promises to support the opposition to the Sandinista regime in Nicaragua, but the Democratic majority in the House of Representatives quickly lost faith in the Contra forces’ military acumen. As a result, the Boland Amendments were attached to subsequent defence appropriations bills between 1983 and 1986 in order to guarantee two things: that the Department of Defense and the CIA could no longer disburse funds in support of the Contras and that President Reagan would have no choice but to sign these restrictions into law due to procedural constraints on the Presidential veto.
The first Boland Amendment had no real impact on the activities of the Contras. The insurgents were emboldened by the White House’s support, regardless of Congress’s position. 1983 brought a new level of violence to the conflict, marked by “summary executions of Sandinista soldiers and other brutal measures, […] ‘spectacular’ guerilla assaults, [and] air strikes on Sandino airport near Managua and other targets.” During the period between the passage of the first Boland Amendment and the second, the CIA continued to support the Contra movement with arms, intelligence, matériel, the deployment of nautical mines, and air support.
When Reagan’s CIA undertook its covert action to support the Contras, plausible deniability would return to the forefront of presidential strategy in shielding the chief executive from political fallout precipitated by the intelligence community. President Reagan’s first public address discussing the Iran-Contra affair carefully tread the line between fact and farce, denying the U.S. had any role in the arms trade and distancing the White House from any participation in the Nicaraguan Contra war. Specifically, Reagan overtly denied “that the Congress, as well as top Executive Branch officials, were circumvented.”
Congress disagreed with Reagan’s characterization. It didn’t take long for their suspicions to be confirmed. By the end of 1983, new evidence revealed that the CIA had continued supporting the Contras directly with public funds. Congress then passed the second Boland amendment as a rider on the FY 1985 Defense Appropriations bill, and President Reagan was forced to reconfigure his Nicaraguan strategy once again.
At this point, the NSC re-enters the picture, as an allotment from the previously-disbursed funds used to provide armament to the Iranians was rechannelled to the Contras by Lt. Col. Oliver L. North on orders from then Vice Adm. John M. Poindexter. The public learned of this diversion “in November 1986 after a plane conveying supplies to the contras was shot down and its pilot taken prisoner by the Sandinistas.” This incident sparked an investigation from the Senate (the Tower Commission), but its limitations proved insurmountable, and it produced no major indictments. In particular, the commission lacked any enforceable mandate to compel testimony from administration personnel. Both Poindexter and North failed to appear, entering no official representation of their role into the public record.
The Contras committed widespread human rights abuses during their brutal campaign of insurgent violence against the Sandinista regime. As a direct result of U.S. involvement, opportunities for peace talks were forestalled, and “torture and indiscriminate killing” were common tactics used to destabilize the seat of Sandinista power in Managua. These abuses were not limited to Nicaragua either. In 1984, the City of San Francisco was ordered by unnamed national security officials to release $36,800 of drug money seized from a Nicaraguan trafficker on the grounds that the cash was expected to be sent to the Contras. In 1987, Ramon Milian Rodriguez (a U.S.-based accountant and money launderer for the Medellín cartel) attested to his role in sending $10 million to the Contras on behalf of the CIA in front of the Senate narcotics and terrorism subcommittee. Throughout the 1980s, the CIA and its Contra network brought cocaine north and returned the proceeds to Nicaragua for use in the fight against the Sandinista government. This scheme eliminated the CIA’s reliance on Congressionally approved funds to support its covert actions, but it also flew in the face of Reagan’s commitment to ‘the War on Drugs,’ showing how the expanded and unaccountable bureaucratic arm of the Presidency made its domestic and foreign policy incoherent.
From start to finish, the Contra affair was almost a decade long program which utilized previously under-utilized tools given to the U.S. President decades before Reagan. Even though the Contras would not succeed in seizing power militarily, their cohort would oust the Sandinistas democratically in the 1990s and bring the saga to an end under the first Bush administration. The Reagan administration’s use (and abuse) of power did not ultimately produce regime change, but it would solidify a new iteration of executive power that remains firmly in place today.
The Failure of Congressional Oversight
Because the U.S. Military’s involvement in Korea and Vietnam was dispatched without congressional approval, Congress tried to reassert its constitutionally enshrined role as the decisive body in permitting or disallowing U.S. participation in foreign wars by passing the 1973 War Powers Act. The key requirements of the law are:
- The President must consult with Congress before “introducing United States Armed Forces into hostilities” and will “consult regularly with the Congress until United States Armed Forces are no longer engaged in hostilities”
- Should the President bring the armed forces into hostile contact without a declaration of war, the President must submit a report explaining the situation to the Speaker of the House of Representatives, and the President Pro Tempore of the Senate within 48 hours.
- The President must “terminate any use of United States Armed Forces” within 60 days of the initial reporting deadline, unless Congressional approval for deployment is extended.
The Reagan administration carefully avoided triggering the War Powers Act during the Contra affair by limiting its boots-on-the-ground activities in Nicaragua to Executive Branch personnel under the CIA and keeping U.S. involvement limited to financial and strategic channels.
Criminal charges were levied against high ranking officials from the Reagan administration, including Robert MacFarlane and four co-defendants, for violating the Boland Amendments. These indictments failed to produce convictions due to a highly effective campaign to frustrate judiciary enforcement. Reagan’s Department of Justice actively defended the President and his collaborators from prosecution, and submitted material in defence of NSC and CIA personnel. Intelligence community leadership also contributed to these post-op manoeuvres by refusing to declassify key documents that would incriminate those accused, breaking the precedent of cooperation between government agencies and the judiciary system.
Congress’s attempts to prosecute the Reagan cabinet were undermined by its “decision to compel immunized testimony” from Lt. Col. North and Vice Adm. Poindexter, the two individuals most directly implicated in the scandal itself. Extending the privilege of immunity in exchange for congressional testimony was not only a poor strategic decision, it was a breach of precedent noted at the time by the Office of Independent Counsel as a serious misstep that jeopardized further pursuit of reprisal or accountability for subordinate personnel at the NSC. When the District Courts attempted to pursue criminal charges against North and Poindexter, the most important articles of evidence were inadmissible in court thanks to Congress’s fumble. As such, nothing concrete ever materialized while the door was still open for indictment.
Creative legal strategies pioneered by future Attorney General William Barr kept Reagan and the rest of his cabinet out of court for the duration of his presidency. Even though the Reagan administration succeeded in keeping its biggest names out of handcuffs, institutional will for prosecution and accountability remained. Congressional leadership still wanted to confirm the coequal nature of the legislative and judiciary branches of the U.S. government, but these hopes were dashed when George H.W. Bush, former Director of the CIA and Reagan’s Vice President, won the 1988 election. Throughout the course of his single term, Bush issued Presidential pardons to Robert MacFarlane and several of his NSC subordinates, as well as senior leadership from the CIA.
The level of popular support that Reagan enjoyed during his presidency is often credited with shielding him from impeachment after the Iran Contra scandal came to light, but this characterization fails to account for the leeway afforded to the U.S. president by the constitution and the legal precedent of judicial deference to the President’s foreign policy. Supreme Court (SCOTUS) cases assessing the limits of the POTUS’s ability to set foreign policy are few and far between, but the cases that have reached SCOTUS trend in the President’s favour. The bifurcation between issues of foreign and domestic policy is a long-standing trend in the U.S. judiciary system, and a statistical analysis of the Supreme Court’s voting patterns from the period of 1949–1993 found that the number of affirmative votes in tests of the President’s foreign policy constraints were significantly higher than contested domestic policy cases over the same period. In other words, the highest court in the U.S. takes a widely permissive stance towards executive authority abroad, in contrast with its approach to governance on the home front.
In this respect, the expansion of Presidential authority, especially over foreign policy, was never effectively curtailed by SCOTUS, undermining the Legislative Branch’s attempts to do so by failing to enforce their directives. Beyond lacklustre enforcement mechanisms, Congress is an ineffective regulatory body because its structure is limited by the U.S. Constitution and its well-defined role works against it when dealing with the fluid and ill-defined executive. The presidency can essentially define and re-define itself continuously, and the incorporation of the NSC within the Executive Branch perfectly encapsulates this reality. Congress cannot rapidly expand its capabilities in tandem with the presidency, because it has codified and binding procedures that keep it static. After the failure of the Tower Commission, which could not even compel the testimony of key witnesses like John Poindexter, it became clear that neither the House nor the Senate could adequately investigate abuses of power, let alone dictate response terms. This procedural inadequacy led to a series of accountability failures that had far seeping consequences beyond the Iran Contra scandal, setting the stage for further expansions of executive power under subsequent administrations.
Conclusion
The Contra affair was a masterclass in executive mismanagement at all levels. Multiple iterations of the U.S. Congress failed to make a concerted effort to re-establish the core principle of American government; the co-equal nature of the three branches of the Federal system. When Congress did attempt to restrain the President, the Judiciary branch was too reluctant to enforce its mandates. As the Executive Branch dramatically expanded its staff and capabilities during the mid 20th century, the sluggish legislature was powerless to sanction the President’s dilation of scope because it was always intended to be representative of a plurality of voices and opinions that slow down progress across the board.
The results speak for themselves. Executive power gave rise to some of the most heinous and problematic manifestations of U.S. empire witnessed in its brief history to date. Human rights abuses abounded, violence and reprisal were considered beneficial policy outcomes, and the exacerbation of conflicts in the Middle East as a result of Reagan’s contradictory foreign policies still have major impacts on the national security ecosystem today.
To answer the titular question of this essay, the full extent of U.S. participation in the Contra affair was undoubtedly made possible by the major structural changes that the Executive Branch underwent after World War II, but it is important to remember that some aspects of the Reagan administration’s conduct were considered fully acceptable by Congress for a while. The anti-communist movement had its supporters outside the White House, and the Boland Amendments were not born out of any high-minded concern for human rights. Instead, a lack of faith in the Contras as an effective opposition movement led Congress to tighten the purse strings. U.S. foreign policy is synonymous with interference in Latin America, and the activities of the NSC and the CIA under Reagan are only unique with regard to the procedural irregularities that enabled a widespread rejection of Congressional oversight.
The events of the 1980s were consistent with the conduct of the United States Federal Government in general, and while the actions of President Reagan and his subordinates during Iran Contra did acutely demonstrate issues with the Executive Branch, they cannot be wholly attributed to any one point of failure in governmental accountability. Rather, the fundamental flaws enshrined in the U.S. Constitution created a situation ripe for exploitation, and the co-evolution of the presidency and the intelligence community handed the Reagan administration the proverbial keys to the castle. It was only a matter of time before someone willing to capitalize on these disparities entered the Oval Office. It happened once before during the Nixon presidency, and the lessons learned after his impeachment let the prudent Reagan team strategize around areas of strength and weakness for Congressional oversight and, ultimately, completely avoid answering for its malfeasances.
While Iran Contra lives on in the memory of the American public, the mechanisms by which it was facilitated were not sufficiently addressed to prevent future abuses. George W. Bush was able to rapidly expand the U.S. surveillance state through the National Security Agency, and although it was created by an act of congress, it became unaccountable due to Reagan’s Executive Order 12333 from 1981. Obama’s transition away from ground operations in Iraq was predicated on the executive authority to authorize drone strikes without congressional approval. And still today, we see tension between overwhelming executive privilege stonewalling attempted prosecutions of January 6th insurrectionists. The expansion of executive authority continues to be a critical issue in U.S. politics, and won’t be resolved as long as the ill-defined structure of the Presidency is returned to its original station as one of three co-equal branches of government.
Works Cited
Bibliography
93rd United States Congress. Joint resolution concerning the War powers of Congress and the President (1973). https://www.law.cornell.edu/uscode/text/50/1542.
Blum, William. “The CIA, Contras, Gangs, and Crack.” Institute for Policy Studies, November 1, 1996. https://ips-dc.org/the_cia_contras_gangs_and_crack/.
Boland, Edward. AMENDMENT TO THE INTELLIGENCE AUTHORIZATION ACT FOR FISCAL YEAR 1983 (THE BOLAND AMENDMENT), 801 § (1982). https://www.brown.edu/Research/Understanding_the_Iran_Contra_Affair/documents/d-nic-7.pdf.
Cheit, Ross. “Understanding the Iran-Contra Affairs — Nicaragua.” www.brown.edu, 2012. https://www.brown.edu/Research/Understanding_the_Iran_Contra_Affair/n-contrasus.php.
Crenson, Matthew A, and Benjamin Ginsberg. Presidential Power : Unchecked and Unbalanced. New York: W.W. Norton, 2008.
Executive Order 12333 — United States Intelligence Activities (1981). https://www.archives.gov/federal-register/codification/executive-order/12333.html.
Feinman, Ronald. “The Expansion of Presidential Power since 1973 | History News Network.” historynewsnetwork.org, May 26, 2018. https://historynewsnetwork.org/article/172065.
Goodwin, Zachary. “U.S. Involvement in the 1980s Iran-Iraq War: America’s Haphazard Extension of Gulf Insecurity.” Yris.Yira.org. Yale Review of International Studies, 2019. http://yris.yira.org/comments/2729.
History.com Editors. “Sandinistas Are Defeated in Nicaraguan Elections.” HISTORY, July 17, 2019. https://www.history.com/this-day-in-history/sandinistas-are-defeated-in-nicaraguan-elections.
Howe, George. “The Early History of NSA,” n.d. https://www.nsa.gov/portals/75/documents/news-features/declassified-documents/cryptologic-spectrum/early_history_nsa.pdf.
Hunter, Rachel. “Understanding the Iran-Contra Affairs — the Iran-Contra Affairs.” www.brown.edu. Brown University, 2012. https://www.brown.edu/Research/Understanding_the_Iran_Contra_Affair/n-contras.php.
Johnston, James H. Murder, Inc.: The CIA under John F. Kennedy. JSTOR. University of Nebraska Press, 2019. https://www.jstor.org/stable/pdf/j.ctvhrd0vs.5.pdf?refreqid=excelsior%3Ae4531b6e8b6d5453f7b4dacd9c8bad27&ab_segments=&origin=.
King, Kimi Lynn, and James Meernik. “The Supreme Court and the Powers of the Executive: The Adjudication of Foreign Policy.” Political Research Quarterly 52, no. 4 (December 1999): 801. https://doi.org/10.2307/449187.
Laperruque, Jake. “Executive Order 12333: The Spy Power Too Big for Any Legal Limits.” Project On Government Oversight, March 24, 2022. https://www.pogo.org/analysis/2022/03/executive-order-12333-the-spy-power-too-big-for-any-legal-limits/.
Matthews, Roland. “Iran-Contra Affair | Summary.” In Encyclopædia Britannica, February 7, 2019. https://www.britannica.com/event/Iran-Contra-Affair.
Miron, Marina. “How Important Was the CIA for Ronald Reagan’s Foreign Policy?,” June 7, 2019. https://osf.io/8hdtg/.
Moore, Erik A. “Rights or Wishes? Conflicting Views over Human Rights and America’s Involvement in the Nicaraguan Contra War.” Diplomacy & Statecraft 29, no. 4 (October 2, 2018): 716–37. https://doi.org/10.1080/09592296.2018.1528789.
NSDD 17: National Security Decision Directive on Cuba and Central America (1982). https://irp.fas.org/offdocs/nsdd/nsdd-17.pdf.
Purkiss, Jessica, and Jack Serle. “Obama’s Covert Drone War in Numbers: Ten Times More Strikes than Bush.” The Bureau of Investigative Journalism, January 17, 2017. https://www.thebureauinvestigates.com/stories/2017-01-17/obamas-covert-drone-war-in-numbers-ten-times-more-strikes-than-bush.
Reagan Library. “President Reagan’s Address to the Nation on the Iran-Contra Controversy, November 13, 1986.” www.youtube.com. Reagan Library, November 13, 1986. https://youtu.be/rYdvBZxPhLY.
Richard Nixon Library. “War Powers Resolution of 1973 | Richard Nixon Museum and Library.” www.nixonlibrary.gov, July 27, 2021. https://www.nixonlibrary.gov/news/war-powers-resolution-1973.
Savage, Charlie. “Trump’s Claim of Executive Privilege in the Jan. 6 Inquiry, Explained.” The New York Times, October 19, 2021, sec. U.S. https://www.nytimes.com/2021/10/19/us/politics/trump-executive-privilege.html.
The Editors of Encyclopedia Britannica. “Monroe Doctrine | History, Elements, & Facts.” In Encyclopædia Britannica, January 30, 2019. https://www.britannica.com/event/Monroe-Doctrine.
The Washington Post. “DRUG FIGURE SAYS CARTEL GAVE FUNDS to CONTRAS.” Washington Post, 1987. https://www.washingtonpost.com/archive/politics/1987/06/30/drug-figure-says-cartel-gave-funds-to-contras/b11f3891-37df-4819-88e7-1a4ce1f45e8e/.
U.S. Department of Justice. “Pardons Granted by President George H. W. Bush (1989–1993).” www.justice.gov, January 12, 2015. https://www.justice.gov/pardon/pardons-granted-president-george-h-w-bush-1989-1993.
USDOJ/OIG. “CIA-Contra-Crack Cocaine Controversy.” oig.justice.gov, December 1997. https://oig.justice.gov/sites/default/files/archive/special/9712/index.htm.
Walsh, Lawrence. “Walsh Iran / Contra Report — Part I Iran/Contra: The Underlying Facts.” irp.fas.org. UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT, April 4, 1993. https://irp.fas.org/offdocs/walsh/part_i.htm.
Yates, Jeff, and Andrew Whitford. “Presidential Power and the United States Supreme Court.” Political Research Quarterly 51, no. 2 (June 1998): 539. https://doi.org/10.2307/449090.