
Territory of Guam v. Davis
This case involves a challenge to a Guam law that restricted a plebiscite on the territory's political status to only "Native Inhabitants of Guam," which the lower courts found violated the Fifteenth Amendment's prohibition on racial discrimination in voting.
- Status
- Decided
- Appeal from
- United States Court of Appeals for the Ninth Circuit
- Decision released
- May 4, 2020
Decision briefing
The case in plain English
What Happened
The Supreme Court declined to hear Guam's appeal, which means the lower court's ruling stands. The Ninth Circuit Court of Appeals previously ruled that Guam could not limit a vote on its future political status to only 'Native Inhabitants' because that restriction was based on race.
Why It Matters
This decision prevents Guam from holding a vote that excludes residents who do not meet specific ancestral requirements. It protects the principle that voting rights cannot be restricted based on race or ancestry in U.S. territories.
The Big Picture
The case centers on the Fifteenth Amendment, which stops the government from denying the right to vote based on race. It highlights the ongoing tension between the rights of indigenous groups in territories and federal constitutional protections.
What the Justices Said
The Supreme Court denied the petition for a writ of certiorari (a request to review the case) on May 4, 2020, leaving the lower court's decision in place.
The Bottom Line
Guam cannot use ancestry as a proxy for race to limit who is allowed to vote in a plebiscite (a direct vote by citizens).
What's Next
Lower courts and local officials in Guam must now ensure that any future votes on political status are open to all eligible voters regardless of their ancestry. Legal experts will watch how this affects other territories seeking to define their relationship with the United States.
What was the core dispute in this case?
The dispute was whether Guam could limit a vote on its future political status to 'Native Inhabitants' only. A resident challenged this, arguing it was racial discrimination.
What are the real-world consequences for voters in Guam?
Voters who are not considered 'Native Inhabitants' can no longer be excluded from participating in status votes. This ensures a broader portion of the population has a voice.
What legal rule did the lower court apply to this situation?
The court applied the Fifteenth Amendment, which prohibits denying the right to vote based on race. It found that the term 'Native Inhabitants' acted as a proxy for race.
What is the next procedural step for this case?
Since the Supreme Court refused to hear the case, the legal battle in federal court is over. Parties must now follow the Ninth Circuit's ruling in future elections.
How does this case fit into a broader legal trend?
This case follows a trend of courts strictly enforcing voting equality in U.S. territories. It limits the ability of territorial governments to create ancestry-based voting qualifications.
Where things stand
Timeline
Source note
How this page is sourced
Official case materials anchor this page. Reporting is used only to add context and explain the dispute in plain English.
Page data last refreshed Mar 31, 2026.
Context reporting
Primary materials
Documents & resources
Recent coverage
In the news
More to watch