1982: the non-binding plebiscite
A non-binding plebiscite favoured commonwealth status, with statehood second, on low turnout.[1]
· Referendum or popular consultation
1982 Guam self-determination plebiscite
A non-binding vote on Guam's political status favoured commonwealth status on low turnout.
2000-2020: the Davis v. Guam litigation
The 2000 Plebiscite Law's Native Inhabitant voting restriction was challenged and struck down by the Ninth Circuit in 2019, with certiorari denied in 2020.[2] [3]
· Legal decision
Davis v. Guam Ninth Circuit ruling, 2019
A federal appeals court struck down the race-restricted plebiscite voter eligibility rule as unconstitutional.
Sources for this page
Each number marks a specific claim. Notes give the source, its locator and how it relates to the claim.
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1.
Claim: Three political-status options have been proposed for a Guam self-determination plebiscite: independence, free association (close association with another nation without incorporation into the United States), and US statehood (which would make Guam the fifty-first state). A non-binding plebiscite held in January 1982 asked a broader set of status questions and showed overwhelming support for commonwealth status, with statehood in second place, though only a small minority of eligible voters participated.
- CHamoru/Chamorro Quest for Self-Determination (Guampedia) link, Status options and 1982 plebiscite section. Source record
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2.
Claim: Guam's 2000 Plebiscite Law restricted voting in a planned political-status plebiscite to "Native Inhabitants of Guam," defined by reference to persons who became US citizens under the 1950 Organic Act and their descendants; this restriction was challenged in Davis v. Guam by plaintiff Arnold Davis, a Guam resident not qualifying as a Native Inhabitant.
- Challenge to CHamoru Self-determination: Davis v. Guam (Guampedia) link, Plebiscite Law restriction and challenge section. Source record
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3.
Claim: On 29 July 2019, the Ninth Circuit Court of Appeals ruled that Guam's 2000 Plebiscite Law's restriction of voting to Native Inhabitants violated the Fifteenth Amendment, applying the precedents of Rice v. Cayetano and a related Northern Mariana Islands case that had invalidated similar ancestry-based voting restrictions as unconstitutional proxies for race; the US Supreme Court denied certiorari in 2020, and the plebiscite as configured was permanently enjoined. No legally binding plebiscite on Guam's political status has been completed.
- Davis v. Guam Court of Appeals Decision (US Department of Justice, Civil Rights Division) link, Ninth Circuit ruling and injunction section. Source record
Printed from https://independenceatlas.com/movements/guahan-guam-self-determination/history · last substantive update 24 September 2026.