Conditional Treatment Recommendations Render First-Time Methamphetamine Sentences Illegal Under 9 GCA § 67.401.12 Case: People of Guam v. Colleen Sherise Castillon Yurko, 2026 Guam 9 (Supreme Court...
Probation-Revocation Sentencing: No Separate On-the-Record Justification Required to Impose the Statutory Maximum Under 9 GCA § 80.66(b) I. Introduction In People of Guam v. Michael John Toves...
Discovery Is Not GRE 404(b) Notice: Failure to Provide Requested Notice Renders Other-Acts Evidence Inadmissible and Can Require Reversal Case: People of Guam v. Philips James Sablan, Cite: 2026 Guam...
Circumstantial Proof of Intent Suffices for Attempted CSC IV, and Consecutive Sentences with Abuse of an Incompetent Do Not Violate Guam’s Double Jeopardy Statutes I. Introduction In People of Guam...
Pro Se Named Executor May Petition for Letters Testamentary Without Counsel; Lack of a Law License Is Not “Improvidence” or “Want of Understanding” In the Matter of the Estate of Jose Aguon...
Unscreeened Public Defender Office Conflicts: Actual Conflict, Presumed Prejudice, and Office-Wide Disqualification When a Managing Attorney Remains Involved Case: People of Guam v. Ben Castro...
“Receipt” Means Actual Receipt: Ten-Day Response Periods in GWA Adverse Actions Run from Delivery, Not Mailing I. Introduction In Guam Waterworks Authority v. Civil Service Commission, and Joey A....
Port Authority of Guam v. Guam Shipyard: Unlawful Detainer Reaches Terminated Licensees; Alternative Rent Pleading Doesn’t Defeat a Holdover Claim; Five-Day Answer Period After a Denied Motion to...
Hung-Jury Retrial Rule in Guam: 9 GCA § 1.24(d)(2) as an Independent Double-Jeopardy Safe Harbor; No Implied Acquittal Where the Record Shows Deadlock People of Guam v. Louis Anthony Vargas, 2026...
CSC II “Sexual Contact” Requires Only a Reasonably Construed Sexual Purpose (Not Actual Gratification), and “Two-Inference” Reasonable-Doubt Language Is Not Required I. Introduction In People of Guam...
Section 8130(a)(2) “Service Retirement Annuity” Electors Are Excluded from Section 8134 Surviving Spouse Annuities Absent an Express Statutory Extension Case: Takako B. Guthrie and Joseph A. Guthrie,...
Unlimited Statute-of-Limitations Waivers in Guam Promissory Notes Are Unenforceable Absent Statutory Authorization I. Introduction In Goodwind Development Corporation v. West Bay Corporation and 21st...
Guam Adopts Maryland v. Craig as the Governing Sixth Amendment Standard for Two-Way Remote Testimony by Adult Witnesses (Rejecting a Categorical Deposition Requirement) I. Introduction In People of...
Silent Record Bars Direct-Appeal McCoy Relief: Objection Must Appear in the Record; Otherwise the Concession-of-Guilt Claim Proceeds by Habeas Case: People of Guam v. Brian Jason Martinez (aka Brenda...
GRE 1004(1) and Missing Surveillance Video: Third-Party Destruction Excuses the Original, and Secondary Evidence Has No Hierarchy Even If Police Destroy a Duplicate 1. Introduction People of Guam v....
Guam Adopts a Flexible McDonough Juror-Bias Framework, Confines Implied Bias to “Extreme” Cases, and Approves Non‑Corroboration Instructions in CSC Trials Case: People of Guam v. Derick James...
Settlor Intent, Charitable Beneficiaries, and Limits on Trustee Removal under Guam Law: Commentary on Kamlesh K. Hemlani v. Manu & Anita Melwani, 2025 Guam 12 I. Introduction The Supreme Court of...
People of Guam v. Narruhn: Direct Review Limits on Ineffective Assistance Claims and Scrutiny of DNA Evidence in Micronesian Prosecutions Introduction The Supreme Court of Guam’s decision in People...
Jurisdictional Limits on the Office of Public Accountability in Debarment Matters: Commentary on SH Enterprises, Inc. v. Territory of Guam, 2025 Guam 10 I. Introduction The Supreme Court of Guam’s...
Limiting Multiple CSC Convictions for a Single Sexual Act under 9 GCA § 1.22(e): A Comprehensive Commentary on People of Guam v. Castro, 2025 Guam 9 I. Introduction The Supreme Court of Guam’s...