Gutierrez v. Ada
The Supreme Court ruled that Guam's law requiring a governor and lieutenant governor to win 'a majority of the votes cast in any election' means a majority of votes cast for that office, not a majority of every ballot cast in the whole general election.
Because the winning slate had a majority of votes cast for governor even though it fell short of half of all ballots cast that day, no runoff election was required, reversing a lower court order for a new election.
“words and people are known by their companions.”
Souter explains the interpretive rule used to figure out what 'any election' meant in the statute.
How it got here: A federal district court in Guam ordered a runoff election; the Ninth Circuit affirmed; the Supreme Court granted review to resolve a conflict with the Third Circuit's reading of identical Virgin Islands law.
The Case in Depth
What happened
In Guam's 1998 general election, one slate for governor and lieutenant governor won more votes than its opponent, but thousands of voters who cast ballots for other offices left the governor's race blank. Guam's election commission certified the leading slate as the winner. The losing slate sued, arguing the law required a majority of every ballot cast that day, not just a majority among those who voted for governor.
The question before the Court
When Guam voters cast ballots for many offices at once, did a governor's slate need a majority of all ballots cast that day, or just a majority of votes cast for governor?
Why it matters
The ruling let Guam's elected governor and lieutenant governor take office without a costly, disruptive runoff election, even though many voters left the governor's race blank or voted for other offices. It also clarifies, for Guam and the Virgin Islands (which use identical statutory language), how election officials should count votes when deciding if a runoff is required.
What changes now
The case is sent back to the lower courts for further proceedings consistent with the Supreme Court's reading of the statute, meaning no runoff election is required and the previously certified winners' election stands. The ruling also resolves how identical language in the Virgin Islands' election law should be read, since the Court took the case specifically to settle a disagreement between two federal appeals courts.
How the Court got there
The legal reasoning, step by step
- The Court applied the interpretive principle that 'a word is known by the company it keeps,' looking at how the disputed phrase 'any election' was surrounded by six other references to the governor's election within the same statutory provision.
- Because the phrase 'any election' sat between repeated mentions of the gubernatorial election specifically, the Court read it as referring to that same election rather than to the broader general election covering many offices.
- The Court noted Congress used a different, more specific term ('general election') elsewhere in the same law, and reasoned Congress would not have used the vaguer 'any election' to mean the same thing it labeled 'general election' just a few lines later.
- The Court also compared the statute to a separate law governing Guam's delegate to Congress, which used the word 'ballot' when it meant to count every ballot cast, showing Congress knows how to say 'ballots' when that is what it means, and did not do so here.
- The Court found the losing slate's reading would be an oddly harsh way to select an official, potentially forcing a runoff even when one slate held a clear majority of everyone who expressed any preference for governor, and noted it would sit awkwardly next to a separate recall statute pegged to votes actually cast for the officeholder.
- The Court concluded that a rule against reading statutory language as redundant did not outweigh these clues, since the phrase still served the modest purpose of confirming the majority requirement applied to both the first gubernatorial election and later ones.