Limtiaco v. Camacho
2007 United States Supreme Court case / From Wikipedia, the free encyclopedia
Limtiaco v. Camacho (2007),[note 2][note 3] 549 U.S. 483, is a case of the United States Supreme Court which handled a complex taxation dispute between two Guamanian politicians—Douglas B. Moylan, Guam's first elected Attorney General, and Felix P. Camacho, then-Governor of Guam—involving the proper interpretation of the Guam Organic Act. Guam, an unincorporated territory of the United States, is governed by this Organic Act, a United States federal law passed in 1950; much case law in the territory is based on its interpretation.
Limtiaco v. Camacho | |
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Argued January 8, 2007 Decided March 27, 2007 | |
Full case name | Alicia G. Limtiaco, Attorney General of Guam, v. Felix P. Camacho, Governor of Guam |
Docket no. | 06-116 |
Citations | 549 U.S. 483 (more) |
Argument | Oral argument |
Opinion announcement | Opinion announcement |
Case history | |
Prior | 2003 Guam 16 |
Procedural | Writ of certiorari to the Supreme Court of Guam[note 1] |
Holding | |
The Supreme Court of Guam erred as to the interpretation of its own Organic Act, a federal statute which must be "construed according to its terms". Tax assessment value must be used to calculate Guam's debt ceiling, not market value. | |
Court membership | |
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Case opinions | |
Majority | Thomas, joined by Roberts, Scalia, Kennedy, Breyer |
Dissent | Souter, joined by Stevens, Ginsburg, Alito |
Laws applied | |
Guam Organic Act |
The case focused on a seemingly narrow issue: whether for the purposes of the debt ceiling established in § 11 of the Guam Organic Act—ten percent of the value of real property in Guam—the real (market) value or tax (assessed) value was to be used to calculate the ceiling. Moylan argued that one must use the tax value (a considerably smaller number, as public buildings had a tax valuation of US$0),[note 4] while Camacho argued the appraisal value must be used instead.
In a 5–4 ruling,[note 5] the Supreme Court reversed the decision of the Guam Supreme Court, finding for the Office of the Attorney General of Guam. While the case was originally brought by Moylan to promote fiscal conservatism, ironically, when it reached the Supreme Court of the United States, the minority remarked in its dissent that actually the Government of Guam could, sua sponte, sidestep the debt ceiling by doubling the assessed value of property while halving the tax rate of that same property in one Public Law, entirely contrary to Moylan's stated goals of enforcing federal sovereignty in the unincorporated territory. While the Court found this outcome unlikely, it was put into practice by Guam's government soon after the case was decided; by 2009, Guam had done so twice.