Limtiaco v. Camacho (2006)
- Docket
- 06-116
- Decided
- 2006-01-01
Summary
Question: 1) Did the Supreme Court of Guam err in interpreting the phrase "aggregate tax valuation" in the Guam Organic Act to mean the full value of property on Guam rather than the assessed value for the purposes of taxation? 2) Does the time the case was pending before the U.S. Court of Appeals count toward the time limit for seeking Supreme Court review? Conclusion: Yes and no. The Court agreed unanimously that the time the case was pending in the Ninth Circuit did not count toward the 90-day time limit for Supreme Court appeals, though this ruling was limited to the "unique procedural circumstances" presented by the case. On question of the interpretation of "tax valuation" in the Organic Act of Guam, the Court split 5-4. The majority opinion by Justice Clarence Thomas held that, contrary to the Guam Supreme Court's interpretation, the phrase must mean the assessed value for tax purposes of property on Guam. "The word 'tax' modifies 'valuation,' not 'property,'" the Court reasoned, so "tax valuation" "refers to the type of valuation to be conducted, not the object that is valued." The dissenting Justices argued that deciding the case on the basis of textual analysis and comparison to state debt limitations would amount to a "coin toss." In the dissenters' view, Congress's purpose was to set a "hard cap" on debt, which would indicate that the debt limitation should be based on the full market (appraised) value of property on Guam rather than dependent on the changeable assessment rate.