Government of Guam v. Cruz

SKOPIL, Circuit Judge:

We are presented with a land dispute claim that turns on the interpretation of Guam Civ.Code § 1157.93 (1970). We must determine whether that statute allows parties to relitigate a property boundary dispute when a mistake may have occurred in prior litigation between the same parties. The district court held that section 1157.93 allowed relitigation in this case. We disagree and reverse.

FACTS AND PRIOR PROCEEDINGS

The Government of Guam (“Guam”) and Ramon and Eliza Cruz (“Cruz”) own adjoining properties. Their respective certificates of title indicate overlapping…