LIMTIACO, ATTORNEY GENERAL OF GUAM v. CAMACHO, GOVERNOR OF GUAM

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483 OCTOBER TERM, 2006
Syllabus
LIMTIACO, ATTORNEY GENERAL OF GUAM v.
CAMACHO, GOVERNOR OF GUAM
certiorari to the supreme court of guam
No. 06–116. Argued January 8, 2007—Decided March 27, 2007
The Guam Legislature authorized the Governor to issue bonds to fund the
Territory’s continuing obligations, but Guam’s attorney general refused
to sign the necessary contracts, concluding that issuance would violate
the debt-limitation provision of Guam’s Organic Act, which limits the
Territory’s public indebtedness to 10 percent of the “aggregate tax valu
ation of the property in Guam,” 48 U. S. C. § 1423a. The Governor
sought a declaration from the Guam Supreme Court that issuance would
not violate the provision, calculating the debt limitation based on the
appraised value of property in Guam. Agreeing, the Supreme Court
rejected the attorney general’s argument to base the limitation on as
sessed value. The Ninth Circuit granted the attorney general’s certio
rari petition, but while the appeal was pending, Congress removed the
Circuit’s jurisdiction over appeals from Guam. Relying on its holding
in Santos v. Guam, that Congress had stripped it of jurisdiction over
pending appeals, the court dismissed the appeal. The attorney general
then filed a petition for certiorari in this Court, even though it was more
than 90 days after the Guam Supreme Court’s judgment.
Held:
1. The Guam Supreme Court’s judgment did not become final, for pur
poses of this Court’s review, until the Ninth Circuit issued its order
dismissing the appeal. Certiorari petitions must be filed “within 90
days after the entry of,” 28 U. S. C. § 2101(c), a lower court’s “genuinely
final judgment,” Hibbs v. Winn, 542 U. S. 88, 98. In some cases, the
actions of a party or a lower court suspend the finality of a judgment
by “rais[ing] the question whether the court will modify the judgment
and alter the parties’ rights.” Ibid. By granting the petition for cer
tiorari, the Ninth Circuit raised that possibility and thus suspended the
finality of the Guam Supreme Court’s judgment. Until the Circuit is
sued its order dismissing the case, the appeal remained pending, and
the finality of the judgment remained suspended. Contrary to the Gov
ernor’s arguments, the judgment was not made final either when Con
gress enacted the jurisdiction-depriving statute or when the Ninth Cir
cuit decided Santos. This holding is limited to the unique procedural
circumstances here. Pp. 487–488.

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Syllabus
2. Guam’s debt limitation must be calculated according to the as
sessed valuation of property in the Territory. The term “tax valuation”
most naturally means the value to which the tax rate is applied. It
therefore means “assessed valuation”—a term consistently defined as a
valuation of property for tax purposes. Appraised value is simply mar
ket value, which may or may not relate to taxation. The Guam Su
preme Court’s contrary interpretation—that “tax” limits the kinds of
property qualifying for inclusion in the debt-limitation calculation—im
permissibly rearranges the statutory language. “Tax” modifies “valua
tion,” not “property.” Thus, “tax valuation” refers to the type of valua
tion to be conducted, not the object that is valued. The court also erred
in reasoning that, because the Virgin Islands’ debt-limitation provision
explicitly refers to “assessed value,” Congress must have intended to
base Guam’s limitation on some other value. Congress’ rejection of “as
sessed” says no more than its rejection of “actual” or “appraised,” terms
it could have used had it meant actual, market, or appraised value.
This Court’s interpretation comports with most States’ practice of fixing
the debt limitations of municipalities to assessed valuation. States use
clear language when departing from this approach, but Congress has
not done so here. The Governor’s additional arguments—that this in
terpretation would result in no debt limitation at all because Guam may
arbitrarily set its assessment rate above 100 percent of market value,
and that this Court owes deference to the Guam Supreme Court’s inter
pretation of the Organic Act—are not persuasive. Pp. 488–492.
Reversed and remanded.
Thomas, J., delivered the opinion for a unanimous Court with respect
to Part II, and the opinion of the Court with respect to Parts I, III, and
IV, in which Roberts, C. J., and Scalia, Kennedy, and Breyer, JJ.,
joined. Souter, J., filed an opinion concurring in part and dissenting in
part, in which Stevens, Ginsburg, and Alito, JJ., joined, post, p. 492.
Seth P. Waxman argued the cause for petitioner. With
him on the briefs were Randolph D. Moss and Jonathan G.
Cedarbaum.
Beth S. Brinkmann argued the cause for respondent.
With her on the brief were Seth M. Galanter, Seth M. Huf
stedler, Shirley M. Hufstedler, Arthur B. Clark, Rodney J.
Jacob, Daniel M. Benjamin, Kathleen V. Fisher, and Arne
D. Wagner.

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485 Cite as: 549 U. S. 483 (2007)
Opinion of the Court
Justice Thomas delivered the opinion of the Court.
The Legislature of Guam authorized Guam’s Governor to
issue bonds to fund the Territory’s continuing obligations.
Concluding that the bonds would violate the debt-limitation
provision of the Organic Act of Guam, § 11, 64 Stat. 387, as
amended, 48 U. S. C. § 1423a, the attorney general 1 of Guam
refused to sign contracts necessary to issue the bonds. In
response, the Governor sought a declaration from the Guam
Supreme Court that issuance of the bonds would not violate
the Organic Act’s debt limitation. The Guam Supreme
Court held that § 1423a limits Guam’s allowed indebtedness
to 10 percent of the appraised valuation, not the assessed
valuation, of taxable property in Guam. We granted certio
rari to decide whether Guam’s debt limitation must be calcu
lated according to the assessed or the appraised valuation of
property in Guam. We hold that it must be calculated based
on the assessed valuation.
I
In 2003, Guam lacked sufficient revenues to pay its obliga
tions. To supplement revenues, the Guam Legislature au
thorized the Governor to issue bonds worth approximately
$400 million. See Guam Pub. L. 27–019. The Governor
signed the new legislation and prepared to issue the bonds.
However, under Guam law, Guam’s attorney general must
review and approve all government contracts prior to their
execution. Guam Code Ann., Tit. 5, § 22601 (1996). The at
torney general concluded that issuance of the bonds would
raise the Territory’s debt above the level authorized by
Guam’s Organic Act. See 48 U. S. C. § 1423a (prohibiting
debt “in excess of 10 per centum of the aggregate tax valua
tion of the property in Guam”). He therefore refused to ap
prove the bond contracts.
1 At the time suit was filed, Douglas Moylan served as Guam’s attorney
general. Alicia Limtiaco has since been elected to the position, and she
continues the case in Moylan’s place.

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In response, the Governor sought a declaration from the
Guam Supreme Court that issuance of the authorized bonds
would not cause Guam’s debt to exceed the debt limitation.
That determination turned, in part, on the meaning of the
phrase “aggregate tax valuation” in Guam’s Organic Act.
The attorney general calculated the debt limitation as 10
percent of the assessed valuation of property in Guam. But
the Governor calculated the debt limitation as 10 percent of
the appraised valuation. Because Guam assesses property
at 35 percent of its appraised value, Guam Code Ann., Tit.
11, § 24102(f), the attorney general’s interpretation resulted
in a much lower debt limit. The Guam Supreme Court
agreed with the Governor and held that 48 U. S. C. § 1423a
sets the debt limitation at 10 percent of the appraised valua
tion of property in Guam.
The attorney general filed a petition for certiorari in the
United States Court of Appeals for the Ninth Circuit. See
§ 1424–2 (granting Ninth Circuit jurisdiction over appeals
from Guam). The Court of Appeals granted the petition in
October 2003. While the appeal was pending, Congress
amended § 1424–2 and removed the language that vested ju
risdiction in the Ninth Circuit over appeals from Guam. See
§ 2, 118 Stat. 2208, 48 U. S. C. § 1424–2 (2000 ed., Supp. IV).
In Santos v. Guam, 436 F. 3d 1051 (Jan. 3, 2006), the Court
of Appeals addressed the effect of the amendment on its ju
risdiction. The court held that Congress had stripped its
jurisdiction not only prospectively, but also for pending ap
peals. Id., at 1054. Citing Santos, the Ninth Circuit dis
missed the attorney general’s appeal in this case on March
6, 2006. See App. to Pet. for Cert. 39a.
The attorney general then filed a petition for certiorari
in this Court. By statute, certiorari petitions must be filed
“within ninety days after the entry of . . . judgment” in a
lower court. 28 U. S. C. § 2101(c). The attorney general
filed his petition more than 90 days after the judgment from

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Opinion of the Court
which he appeals—that of the Guam Supreme Court—was
entered. Accordingly, when we granted certiorari in this
case, 548 U. S. 942 (2006), we directed the parties to address
both the question presented by petitioner and whether the
filing of a petition for certiorari or the pendency of a writ of
certiorari before the Court of Appeals suspended the finality
of the Guam Supreme Court’s judgment for purposes of the
90-day period set out in § 2101(c).
II
Only “a genuinely final judgment” will trigger § 2101(c)’s
90-day period for filing a petition for certiorari in this Court.
Hibbs v. Winn, 542 U. S. 88, 98 (2004). In most cases, the
90-day period begins to run immediately upon entry of a
lower court’s judgment. In some cases, though, the actions
of a party or a lower court suspend the finality of a judgment
and thereby reset the 90-day “clock.” Ibid. For instance,
the timely filing of a petition for rehearing with the lower
court or a lower court’s appropriate decision to rehear an
appeal may suspend the finality of a judgment by “rais[ing]
the question whether the court will modify the judgment and
alter the parties’ rights.” Ibid. (citing Missouri v. Jenkins,
495 U. S. 33, 46 (1990)). So long as that question remains
open, “ ‘there is no “judgment” to be reviewed,’ ” Hibbs,
supra, at 98 (quoting Jenkins, supra, at 46), and § 2101(c)’s
90-day period does not run.
The same reasoning applies here. In 2003, the Court of
Appeals appropriately exercised discretionary jurisdiction
over the attorney general’s appeal. See 48 U. S. C. § 1424–2.
By granting the petition for certiorari, the Ninth Circuit
raised the possibility that it might “modify the judgment” or
“alter the parties’ rights.” Hibbs, supra, at 98. Thus, the
Court of Appeals’ grant of certiorari suspended the finality
of the Guam Supreme Court’s judgment and prevented the
90-day clock from running while the case was pending before

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the Court of Appeals. And until the Ninth Circuit issued
its order dismissing the case, the appeal remained pending,
and the finality of the judgment remained suspended.
The Governor argues that the judgment was made final
earlier—either when Congress enacted the statute depriving
the Court of Appeals of jurisdiction or when the Court of
Appeals decided in Santos that the statute applied to pend
ing cases. But when Congress removed the Ninth Circuit’s
jurisdiction over appeals from Guam, it did not dismiss this
appeal. Likewise, when the Ninth Circuit determined in
Santos that Congress had stripped its jurisdiction over
pending appeals, the court did not finally determine the
rights of the parties in this case. The jurisdiction-stripping
statute and Santos may have signaled the Court of Appeals’
ultimate dismissal of the appeal, but neither created a final
judgment in the still-pending case. The attorney general’s
appeal remained pending until the Ninth Circuit issued its
dismissal order. And the pendency of the appeal continued
to “raise the question whether” any further action by the
court might affect the relationship of the parties. Hibbs,
supra, at 98. Accordingly, we hold that the judgment of the
Guam Supreme Court did not become final, for purposes of
this Court’s review, until the Court of Appeals issued its
order dismissing the appeal.
We emphasize that our holding is limited to the unique
procedural circumstances presented here. Specifically, our
holding does not extend to improperly filed appeals or filings
used as delaying tactics. See Morse v. United States, 270
U. S. 151 (1926) (holding that second application for leave to
file motion for new trial did not suspend the finality of the
lower court’s judgment).
III
Having determined that we have jurisdiction, we turn to
the merits. As always, we begin with the text of the stat
ute. See Nebraska Dept. of Revenue v. Loewenstein, 513
U. S. 123, 128 (1994). Guam’s Organic Act states that “no

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public indebtedness of Guam shall be authorized or allowed
in excess of 10 per centum of the aggregate tax valuation of
the property in Guam.” 48 U. S. C. § 1423a. The present
dispute centers on the meaning of the term “tax valuation.”
In its unmodified form, the word “valuation” means “[t]he
estimated worth of a thing.” Black’s Law Dictionary 1721
(4th ed. 1951) (hereinafter Black’s). But as the parties’ com
peting interpretations demonstrate, there are different sorts
of valuations. An appraised valuation is the market value
of property. See id., at 129 (defining “appraise” as “to fix
and state the true value of a thing”). By contrast, an “as
sessed valuation” is the “[v]alue on each unit of which a pre
scribed amount must be paid as property taxes.” Id., at 149.
These two kinds of valuation are related in practice because
a property’s assessed valuation generally equals some per
centage of its appraised valuation. See, e. g., Guam Code
Ann., Tit. 11, § 24102(f) (defining “value” as “thirty-five per
cent (35%) of the appraised value”). The assessed valuation
therefore could, but typically does not, equal the market
value of the property.
Though it has no established definition, the term “tax valu
ation” most naturally means the value to which the tax rate
is applied.2 Were it otherwise, the modifier “tax” would
have almost no meaning or a meaning inconsistent with ordi
nary usage. “Tax valuation” therefore means “assessed val
uation”—a term consistently defined as a valuation of prop
erty for purposes of taxation. See Black’s 149; see also id.,
at 116 (6th ed. 1990) (defining “assessed valuation” as “[t]he
worth or value of property established by taxing authorities
on the basis of which the tax rate is applied”).
2 The Guam Legislature passed a law attempting to define the term “tax
valuation.” See Guam Code Ann., Tit. 11, § 24102(l), available at http://
www.guamcourts.org/justicedocs/index.html (as visited Mar. 16, 2007).
But that term appears in Guam’s Organic Act, which is a federal statute.
As the Guam Supreme Court correctly determined, Guam’s territorial leg
islature cannot redefine terms used in a federal statute.

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One would not normally refer to a property’s appraised
valuation as its “tax valuation.” Appraised valuation is
simply market value. And market value may or may not
relate to taxation. Usually market value becomes relevant
to taxation only because a specified percentage of market
value is the assessed value to which taxing authorities apply
the tax rate. It would strain the text to conclude that “tax
valuation” means a valuation a step removed from taxation.
The Guam Supreme Court reached a contrary conclusion
by interpreting the word “tax” to limit the kinds of property
that qualify for inclusion in the debt-limitation calculation.
But that interpretation impermissibly rearranges the statu
tory language. The word “tax” modifies “valuation,” not
“property.” The phrase “tax valuation” therefore refers to
the type of valuation to be conducted, not the object that
is valued.
The Guam Supreme Court also contrasted 48 U. S. C.
§ 1423a’s language with explicit references to “assessed valu
ation” in the debt-limitation provision for the Virgin Islands.
See § 1403 (“aggregate assessed valuation”). The court rea
soned that, by using language in § 1423a that differed from
that used in the Virgin Islands’ debt-limitation provision,
Congress expressed its intent to base Guam’s debt limitation
on something other than assessed value. We disagree.
Certainly, Congress could have used the term “assessed val
uation.” But if Congress had meant actual, market, or ap
praised value, it could have used any one of those terms as
well. See N. W. Halsey & Co. v. Belle Plaine, 128 Iowa 467,
104 N. W. 494 (1905) (interpreting debt-limitation provision
using phrase “actual value”). Or it could have left the word
“valuation” unmodified: State courts interpreting other
debt-limitation provisions have understood “valuation,”
standing alone, to mean the market or cash value of property.
See, e. g., Board of Ed., Rich Cty. School Dist. v. Passey, 122
Utah 102, 104–106, 246 P. 2d 1078, 1079 (1952). At least in

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this context, Congress’ rejection of “assessed” tells us no
more than does its rejection of “actual” or “appraised.”
Our interpretation comports with most States’ practice of
tying the debt limitations of municipalities to assessed valua
tion. See 15 E. McQuillin, Law of Municipal Corporations
§ 41:7, p. 422 (3d ed. rev. 2005) (“Most of the constitutional
and statutory provisions make the assessed value of the tax
able property of the municipality the basis for ascertaining
the amount of indebtedness which may be incurred . . . ”).
States that depart from the majority approach use clear lan
guage to do so. See id., at 424–425 (“The standard is gen
erally the assessed value of the property for taxation, rather
than the actual value, where the two are different; but where
the constitution or statute uses the term ‘actual value,’ such
value governs rather than the taxable value” (citing N. W.
Halsey & Co., supra; footnote omitted)). Congress has not
used such language here. Indeed, as discussed earlier, only
a strained reading of “tax valuation” would suggest a depar
ture from the majority approach.
The Governor suggests that our interpretation would re
sult in no debt limitation at all because Guam may arbitrarily
set its assessment rate above 100 percent of market value.
For two reasons, we think the Governor has overstated
this concern. First, most States have long based their debt
limitations on assessed value without incident. Second, a
strong political check exists; property-owning voters will not
fail to notice if the government sets the assessment rate
above market value.
Finally, the Governor mistakenly argues that we owe def
erence to the Guam Supreme Court’s interpretation of the
Organic Act. It may be true that we accord deference to
territorial courts over matters of purely local concern. See
Pernell v. Southall Realty, 416 U. S. 363, 366 (1974) (review
ing District of Columbia Court of Appeals’ interpretation of
D. C. Code provision). This case does not fit that mold, how
ever. The debt-limitation provision protects both Guamani

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Opinion of Souter, J.
ans and the United States from the potential consequences
of territorial insolvency. Thus, this case is not a matter of
purely local concern. Of course, decisions of the Supreme
Court of Guam, as with other territorial courts, are instruc
tive and are entitled to respect when they indicate how stat
utory issues, including the Organic Act, apply to matters of
local concern. On the other hand, the Organic Act is a fed
eral statute, which we are bound to construe according to
its terms.
IV
For the foregoing reasons, we reverse the judgment of the
Guam Supreme Court and remand the case for proceedings
not inconsistent with this opinion.
It is so ordered.
Justice Souter, with whom Justice Stevens, Justice
Ginsburg, and Justice Alito join, concurring in part and
dissenting in part.
I agree that the petition for writ of certiorari was timely,
and join Part II of the Court’s opinion. I disagree, however,
that the phrase “tax valuation” in the Organic Act of Guam,
§ 11, 64 Stat. 387, as amended, 48 U. S. C. § 1423a, refers un
ambiguously to assessed value. If I could not go beyond
statutory text and the sources relied upon by the Court, a
coin toss would be my only way to judgment. But I look to
congressional purpose, which points to appraised value as
the meaning of the term, leaving me in respectful dissent.
The words “tax valuation” can plausibly be read in either
of the ways the parties suggest: as synonymous with as
sessed value (the way the attorney general and the Court
read them), because it is the assessed value to which the
tax rate is immediately applied, Guam Code Ann., Tit. 11,
§§ 24102(f), 24103 (1996), or as meaning appraised value, be
cause the appraisal is a “valuation” for “tax” purposes. The
Court concedes that the term “tax valuation” has no canoni

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cal definition, ante, at 489,1 and says that the term “valua
tion,” standing alone, means “ ‘[t]he estimated worth of a
thing,’ ” ibid. (quoting Black’s Law Dictionary 1721 (4th ed.
1951); alteration in original). Though taking property’s “es
timated worth” to be its “tax valuation” would make practi
cal sense, the Court believes that construction would read
the word “tax” out of the statute. I do not see the objection,
though. Even if we say “valuation” means actual value, the
word “tax” has a job to do, by specifying that the valuation
in question be the valuation used for tax purposes, thus rul
ing out an appraisal made solely for the purpose of calculat
ing the debt limitation, with its temptation to indulge in cre
ative accounting when money is tight.2 But as I said, seeing
the legitimacy of this reading just leaves us with two textu
ally plausible constructions.
I see no tie-breaker in comparing Guam’s debt limitation
with those of other Territories. In each Territory men
tioned by the parties, when Congress imposed a territorial
debt limitation the assessed value was equal to the actual
value of the property.3 Thus the attorney general can stress
1 The phrase “tax valuation” had been used in debt limitations for other
Territories, see ch. 34, 41 Stat. 1096 (Puerto Rico); ch. 203, 42 Stat. 599
(Philippines), but in each of those Territories the issue in this case was
irrelevant because assessed and appraised values were equal. See infra
this page and 494, and nn. 3–4.
2 Though the Court finds the appraised value to be “a step removed from
taxation,” ante, at 490, the connection of the appraised value to the tax
ultimately imposed is direct enough. It is true that the tax computation
requires multiplying the appraised value by two percentages (first 35 per
cent to get the assessed value, Guam Code Ann., Tit. 11, § 24102(f) (1996),
and then the 0.25 percent tax rate, § 24103) while the assessed value must
only be multiplied by a single percentage. But as a practical matter,
tying the tax to the assessed value ties it to the appraised value: multiply
ing the appraised value by 0.0875 percent (35 percent times 0.25 percent)
will give you the tax every time.
3 48 U. S. C. § 1401a (“[A]ll taxes on real property in the Virgin Islands
shall be computed on the basis of the actual value of such property”); Haw.
Rev. Stat., ch. 98, § 1212 (1905), Lodging of Respondent (Doc. 2b) (“[A]ll

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the significance of assessed value and argue that because the
debt limitation in the other Territories was based on the as
sessed value, the same should be true for Guam. And the
Governor can argue that because the debt limitation in the
other Territories was based on the actual value, that should
go for Guam, too. Nor is the tie to be broken by arguing
that pegging the territorial debt limit to “tax valuation” sug
gests that this Territory was meant to be treated more con
servatively than a limit turning on full value; the suggestion
is balanced by the question (without any answer proposed to
us), why Congress would have wished a more restrictive (or
nominally more restrictive) regime for certain Territories.4
Comparing state practices is no help, either. The Court
says that “States that depart from the majority approach” of
linking debt limitations to assessed value “use clear language
to do so,” ante, at 491, but in the preceding paragraph the
majority recognizes that state courts “have understood ‘val
uation,’ standing alone, to mean the market or cash value of
property,” ante, at 490. So it seems a stretch to suggest
that state laws offer a clear rule that Congress may be pre
real property and all personal property within the Territory shall be sub
ject to an annual tax of one per cent. upon the full cash value of the same”);
An Act to Provide Revenue for the People of Porto Rico, and for Other
Purposes, Tit. I, § 8 (1901), reprinted in Acts and Resolves of the First
Legislative Assembly of Porto Rico 47 (1901), Lodging of Respondent
(Doc. 3) (“All taxable property shall be valued and assessed at its actual
market value”); A Compilation of the Acts of the Philippine Commission,
Tit. 10, ch. 56, § 336(a) (1908), Lodging of Respondent (Doc. 4) (“[T]he
board shall proceed to assess the value of each separate parcel of real
estate and the improvements thereon, if any, at their true value in
money”).
4 The percentage of the valuation at which the various debt limitations
were set likewise provides no basis for inferring that Congress had differ
ent intentions for different Territories. When the Organic Act of Guam
was passed in 1950, each of the debt limitations in the Territories men
tioned in n. 3, supra, was also set at 10 percent of the relevant valuation.
See 48 U. S. C. § 1403 (Virgin Islands); 42 Stat. 116 (Hawaii); ch. 34, 41
Stat. 1096 (Puerto Rico); ch. 203, 42 Stat. 599 (Philippines).

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sumed to have understood as background; better to read the
state cases as products of the specific wording of their partic
ular limitations and the state history of property taxation.
See, e. g., Phelps v. Minneapolis, 174 Minn. 509, 511–514, 219
N. W. 872, 873–874 (1928) (relying on text of limitation, other
related provisions, and history of property taxation); N. W.
Halsey & Co. v. Belle Plaine, 128 Iowa 467, 470–474, 104
N. W. 494, 495–497 (1905) (same). It almost goes without
saying that neither side has cited a state case involving lan
guage and background the same as Guam’s.
In sum, the congressional mind does not emerge from the
words “tax valuation” or any settled construction of that
phrase. Fortunately, though, the purpose of the legislation
does point to a likely reading. The statute itself makes clear
that what Congress meant to provide was a practical guaran
tee against crushing debt on the shoulders of future genera
tions, and insolvency with the inevitable call for a bailout by
Congress. See United States Nat. Bank of Ore. v. Inde
pendent Ins. Agents of America, Inc., 508 U. S. 439, 455
(1993) (“ ‘[L]ook to the [law’s] . . . object and policy’ ” (quoting
United States v. Heirs of Boisdore´, 8 How. 113, 122 (1849))).
The attorney general claims that her reading is a bet
ter fit with these objectives because it ties the legislature’s
ability to incur debt to its willingness to tax. But this is
hardly so. Under the attorney general’s approach (now the
Court’s), the Guam Legislature could double the debt limita
tion without increasing taxes by a single penny, simply by
doubling the assessment rate and cutting the tax rate by
half.5
Although it is arguable that tying the debt ceiling to the
assessed value may to some vague degree enhance legisla
tive accountability by requiring action to raise the debt ceil
5 The specter of mischief extends to an attempt to set the assessment
rate above 100 percent. The Court contends that political or practical
constraints would foreclose this maneuver. See ante, at 491. After to
day’s decision, I suppose we may find out.

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ing as debt piles up, I know of no independent suggestion
that the debt limit was designed to operate as a political
discouragement, not as a hard cap. It would, after all, have
been strange for Congress to set a debt cap to constrain the
Guam Legislature, only to leave the limiting figure subject
to easy manipulation by the legislature. While I know that
actual valuation can be manipulated, too, manipulation of
that figure could only be done by officials acting in bad faith
and subject to an obvious political or judicial challenge. The
Court’s approach, by contrast, gives the legislature a green
light to subvert its own stated limit with a clear conscience.6
The more practical understanding of what must have been
intended is a statute tying the debt limitation to Guam’s ca
pacity to tax property. The actual, market value of prop
erty is the only economic index of Guam’s ability to collect
property taxes to pay its bills,7 the only figure under consid
eration that is fixed in the real world, and the only figure
that provides a genuine limitation. This was the figure em
ployed or required by Congress in each of the other Territo
ries mentioned above, see n. 3, supra, and I presume that its
practical significance was in Congress’s mind when it set the
debt caps for each of them. I see no reason not to attribute
the same practical assessment to Congress in this instance.
I would affirm.
6 The attorney general’s position would be strengthened if the assess
ment rate appeared in the Organic Act itself, for then the legislature would
lack the power to change it. This state of affairs would be analogous to an
assessment rate appearing in a state constitution. See, e. g., Colo. Const.,
Art. X, § 3(1)(b); La. Const., Art. VII, § 18(B). But the Organic Act set
no assessment rate, leaving that up to the Guam Legislature.
7 It is not, of course, the only index of Guam’s capacity to pay its bills;
income taxation is an obvious source of revenue, see 48 U. S. C. §§ 1421i(a)–
(b) (authorizing Guam to collect income tax).