Gutierrez v. Ada
Headline: Court rules Guam law does not require a runoff when a governor–lieutenant slate wins a majority of votes cast for that office, even if it lacks a majority of all ballots cast in the general election.
Holding: The Court held that Guam’s election statute does not require a runoff when a governor–lieutenant slate receives a majority of votes cast for that office, rather than a majority of all ballots cast in the general election.
- Stops a runoff where a gubernatorial slate has a majority of votes cast for that office.
- Lets certified winners stand without holding extra statewide runoff elections in similar circumstances.
- Reduces time and expense of ordering additional elections after general election day.
Summary
Background
In the 1998 Guam general election, one slate of candidates for Governor and Lieutenant Governor received more votes for that office than the opposing slate but did not reach a majority of all ballots cast on election day because many ballots left the gubernatorial line blank. The Guam Election Commission certified the slate that had the majority of votes for governor. Opponents sued and a federal district court ordered a runoff, a decision the Ninth Circuit affirmed, prompting review by the Supreme Court.
Reasoning
The Court addressed whether the phrase “majority of the votes cast in any election” meant a majority of votes cast for the governor’s race or a majority of every ballot cast in the general election. Reading the provision in context, the Court found the surrounding language repeatedly refers to elections for Governor and Lieutenant Governor, so “votes cast” naturally means votes cast for that office, not total ballots. The opinion noted Congress elsewhere distinguished votes for a specific office from ballots, and it rejected arguments that the plain reading would be redundant. The Court therefore concluded no runoff was required.
Real world impact
The ruling means the certified winner who had a majority of votes among those who voted in the gubernatorial contest stands without a runoff in this case. It resolves the immediate dispute, reverses the Ninth Circuit, and will guide how Guam counts majorities in future governor elections, avoiding extra statewide runoffs in similar situations.
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