Territory of Guam v. Sugiyama

I agree that Guam has authority to administer customs in Guam. I disagree, however, with the majority’s conclusion that Congress has delegated to Guam the authority to administer United States customs laws rather than Guam’s own customs laws.1 Contrary to the majority's assertion, the parties have argued at length whether Guam may administer its own customs laws and what substantive law exists authorizing the customs searches.

Both parties agree that because Guam is outside United States customs territory, United States customs laws have no force or effect. Guam need not administer United…