Lee and Joan Holmes v. Director of Revenue and Taxation, Government of Guam

AMENDED OPINION

KOZINSKI, Circuit Judge:

We review a summary judgment for the defendant, the Director of Revenue and Taxation of Guam.

Facts

This case arose in the Northern Marianas and Guam. Guam is a largely self-administered territory of the United States, see 48 U.S.C. § 1421a (1982); and the Northern Marianas are part of the United Nations Trust Territory of the Pacific Islands, administered by the United States, see H.J. Res. 238, 61 Stat. 397 (1947).

In 1975, after long deliberation and extensive negotiations, the United States and the people of the Northern Marianas agreed that the…