Political Reviews

Micronesia in Review: Issues and Events, 1 July 2014 to 30 June 2015 michael bevacqua, monica c labriola, kelly g marsh, clement yow mulalap, tyrone j taitano

Polynesia in Review: Issues and Events, 1 July 2014 to 30 June 2015 mary tuti baker, lorenz gonschor, margaret mutu, christina newport, forrest wade young

171 political reviews • micronesia 185

Guam decolonization on Guam, invoking the legacy of his great-grandfather, who The island bustled with activity on in 1917 gave a speech calling for a many fronts this last year—continuing similar political status change. Calvo efforts toward decolonization, elect- proposed holding a decolonization ing island leadership, preparing for plebiscite in 2017, the one-hundred- the role of hosting the 12th Festival year anniversary of his great-grand of Pacific Arts in 2016, facing ongo- father’s speech. ing militarization as well as numerous The past two administrations other issues such as the return of the (including Calvo’s first term) accom- El Niño weather patterns, which has plished very little with regard to mov- meant once again contending with ing this process forward. The Commis- typhoons on a regular basis. sion on Decolonization was formed in On 1 August 2014, the United 1997; this body is meant to guide the States and the Federated States of decolonization process locally and to Micronesia signed a treaty that for- educate those qualified to vote about mally gave ownership of the deepest the three different future political part of the Marianas Trench to the status options for Guam: integration, Federated States (mv, 12 Aug 2014). free association, and independence. Guam, as an unincorporated terri- The work of the commission has long tory—or, according to the United been hampered by lack of funding. In Nations, a non-self-governing terri- recent years, international lobbying tory—was not consulted, even though efforts, website development, public this treaty affects an area that many meetings, and a series of high school have historically considered part of the debates on the topic were all proposed Mariana Islands. Some of the frustra- but never implemented. tion over Guam’s political status is The rhetoric of decolonization that the people of Guam are generally is nothing new, but there were two not included in discussions about what developments that made the gover- happens in their region, as the island nor’s 2015 State of the Island speech is legally a possession of the United significant. First, when advocating States. decolonization, Calvo broke with This frustration was manifested in a long-standing unwritten rule that the 2015 State of the Island Address the chief executive of the island not by Guam Governor Edward “Eddie” express a personal preference on the Baza Calvo; a large portion of his matter. In the past, governors and speech was devoted to “unfunded other elected officials have avoided mandates and colonialism” (Office expressing their personal choice of Governor, 16 Feb 2015). Calvo regarding Guam’s future political denounced the ways in which Guam, status and instead stated support for despite being excluded from US demo- whatever choice the native inhabi cratic processes, is nonetheless subject tants of the island might make. In to essentially all federal laws and his speech, Calvo diverted from his decisions. He called for new energy prepared remarks and added that he to be infused into the movement for personally supported statehood. He 186 the contemporary pacific • 28:1 (2016) did note, however, that he considered 2013, meaning it could be filed again, any status other than the current one and in May 2015 the US Court of an improvement. Appeals for the Ninth Circuit ruled Second, whereas in the past the that Davis’s case should be heard. Calvo administration only offered Although the right to self-deter- words of support, this year it allo- mination and decolonization is an cated $100,000 to the Commission internationally recognized right, the on Decolonization to be used for the United States does not recognize development of educational materials Guam’s path of self-determination as and programs to precede a plebiscite an international issue. The US federal on decolonization. Democratic Party government has long argued that the members of the Guam Legislature question of Guam’s political status is had been critical of Calvo for provid- internal to the United States. Thus the ing funding only for commission staff Davis case could have serious ramifi- members, the majority of whom were cations in terms of Guam’s decoloni- detailed elsewhere in the Government zation and whether the process will of Guam despite being listed as work- be forced to conform to narrow US ing for the commission. In June 2015, national limits instead of internation- the Commission on Decolonization ally accepted conventions. voted to provide $30,000 to each of The specter of potential unconstitu- the three political status task forces tionality has also had a negative effect in order to begin their outreach and on a once-significant breakthrough in advocacy work. moving forward on decolonization. The work of the Commission on According to international law, the Decolonization and the movement for administering power of a non-self-gov- decolonization in general has been erning territory has the obligation to overshadowed since 2011 by a lawsuit fund educational campaigns in order filed on behalf of Arnold “Dave” to help prepare the colony to take the Davis, a Caucasian US citizen living on next step in its political evolution. For Guam, who has long argued that the decades, the United States has refused plebiscite for political status violates not only to acknowledge this respon- his 14th amendment rights related to sibility but also to support the process voting, as he does not fit the category in general. of “native inhabitant” (Marsh and In 2010, the US Congress passed Taitano 2014, 173). However, “native a law that authorized the US Depart- inhabitant” is not a racial category but ment of Interior (doi) to use its rather refers to those who became US technical assistance funding for public citizens via the passage of the Organic education on self-determination in Act of Guam in 1950. It is a group Guam. This money was not guar- that was historically recognized by the anteed, but it was authorized as an United States; while primarily com- allowable expense. Obtaining this prising Chamorros, it also includes money has proven difficult, however, other ethnicities. Davis’s lawsuit was and recent statements by doi officials dismissed “without prejudice” by hint at their hesitancy to provide any Guam’s chief district court judge in support for self-determination educa- political reviews • micronesia 187 tion because the Department of Justice the Gutierrez-Gumataotao team. In may become involved if Davis’s case the course of the campaign, the team claiming unconstitutionality goes also garnered the support of former forward. First Lady Joann Camacho, wife of Some excitement swept through former Republican Governor Felix the island as issues of being a terri- Camacho (pnc, 15 Sept 2014). Calvo tory of the US were highlighted in a campaigned on his administration’s Last Week Tonight with John Oliver financial record, including the timely episode on hbo (2015). Noted was payment of income tax refunds, the visible absence of the US territories although Gutierrez criticized Calvo for of Guam, Puerto Rico, the US Vir- borrowing an additional $380 million gin Islands, and American Sāmoa in through the bond market with high virtually all aspects of US democratic debt service (mv, 9 Oct 2014). processes owing to Supreme Court Aside from the disadvantage of decisions that were made over one running against an incumbent admin- hundred years ago, when segregation- istration, the Democratic team was ist Jim Crow laws were still considered also outmatched financially. October constitutional. Territories have no star campaign expense reports showed the on the US flag; no voting representa- Calvo-Tenorio teamed had raised $1.3 tive in Congress; and no real participa- million by the midpoint of the cam- tion in the selection of the US presi- paign, while the Gutierrez-Gumatao- dent, who is the commander-in-chief tao team had only collected $193,000 under whom many territorial citizens (kuam, 27 Oct 2014). In the series serve in the US military. While some of debates held during the course of awareness may have been raised as a the campaign, Gutierrez challenged result of the hbo episode, a tangible Calvo to say whether he had given outcome has yet to be seen as of this a tax write-off to any of his family’s writing. businesses and whether he would One of the dominant events of agree to an audit of the tax records. 2014 was the island’s election for The Calvo-Tenorio team vehemently governor, lieutenant governor, the denied the charge and called the alle- Guam Legislature, the US Congress, gation “slanderous” (kuam, 28 Oct and a number of local, nonpartisan 2014). When the votes were totaled, offices. Keeping people on the edge the Calvo-Tenorio team garnered more of their seats was the fact that, just than 60 percent of the vote (gec, days before the July filing deadline, 25 Nov 2014). the Democratic Party team of former Republicans, however, did not fare Governor Carl T C Gutierrez and as well in the races for the US Con- attorney Gary Gumataotao jumped gress and the Guam Legislature. In the into the race to challenge the incum- contest for delegate to the US House bent Republicans, Governor Calvo of Representatives, incumbent Made- and Lieutenant Governor Ray Teno- leine Z Bordallo first handily defeated rio. After numerous meetings with challenger and first-time candidate the Democratic leaders and the rank Matthew Artero in the Democratic and file, Democrats united behind primary and then moved on to a land- 188 the contemporary pacific • 28:1 (2016) slide win against newcomer Repub- and Democrat Dr Nerissa Bretania lican Margaret “Pudding” McDon- Underwood, a former superinten- ald Glover Metcalfe in the general dent of education and wife of former election. Metcalfe had campaigned Congressman Robert A Underwood on issues such as local government (gec, 18 Sept 2014). Soon after the reimbursement for shouldering the general election, Democrats met to impact of migrants from neighboring select the leadership for the incom- US Freely Associated States, known ing Legislature and decided to retain locally as Compact Impact funding, Speaker Judith “Judi” T Won Pat, and the long-pending war reparations Vice Speaker Benjamin J F “BJ” Cruz, for the Guam Chamorros and local Legislative Secretary Tina Rose Muña residents of Guam who suffered a Barnes, and Majority Leader Rory J three-year Japanese occupation during Respicio (kuam, 10 Nov 2014). World War II (mv, 21 Oct 2014). Both Nonpartisan elections were also candidates expressed their support for held for other posts. In the race for the US military buildup, but with res- attorney general, Elizabeth Barrett- ervations. Bordallo stated she did not Anderson unseated incumbent Leo support “a buildup at all costs,” while nardo “Lenny” M Rapadas. Barrett- Metcalfe stated that she favored “the Anderson has previously served as least invasive of plans” for the buildup Superior Court judge, senator, and (kuam, 23 Oct 2014). attorney general when it was an Democrats also successfully appointed position. Also selected retained their 9-6 majority in the were three of the five positions on the Guam Legislature, though there was Consolidated Commission on Utilities some turnover in the membership. (ccu), which supervises the island’s Going into the campaign season, power and water agencies. The cur- Democrats had lost one incumbent rent ccu Chair, Simon Sanchez, was with the passing of former Speaker reelected, and the remaining two seats Vicente “Ben” Cabrera Pangelinan. were filled by new members Francis On the Republican side, freshman Santos and George Bamba. Voters also Michael “Mike” Limtiaco chose not approved the retention of Chief Justice to seek another term. As the votes Robert J Torres and Judge Michael in the general election were totaled, J Bordallo and selected half a dozen two other Republican incumbents, members of the Guam Education Christopher “Chris” M Duenas and Board, which supervises the public Aline A Yamashita, lost their bids for schools (gec, 25 Nov 2014). reelection. They were replaced by very Voters in November also agreed to familiar public figures: Republicans a ballot initiative legalizing the use of James “Jim” V Espaldon and Frank medical marijuana. The initiative went F Blas Jr had served previously as through several legal hurdles to get on senators. New to the Legislature were the ballot, finally requiring a ruling by Republican Mary Camacho Torres, the Guam Supreme Court. The initia- a former Airport and Port Author- tive garnered more than 56 percent of ity general manager and sister of the vote, although it was reported that former Governor Felix P Camacho, full implementation would take sev- political reviews • micronesia 189 eral months (Huffington Post, 4 Nov 42 gold, 27 silver, and 12 bronze med- 2014). als (Guam National Olympic Commit- In July 2014, a state funeral was tee 2014). held for Senator Ben Pangelinan. He Further, in the lead-up to the much- was chair of the powerful Appropria- heralded 2018 fifa World Cup, two tions Committee and had previously qualifying matches were held in Guam served as Speaker. Owing to the in 2015. In a feat that attracted inter- passing of Agat Vice Mayor Agustin national notice, Guam’s soccer team Quintanilla while in office, a special prevailed in both contests, defeating election to succeed him was held first Turkmenistan 1-0 and then India on 6 June 2015; Republican Kevin 2-1. The latter match in particular James Taitague Susuico won a multi- received wide international press candidate race for the post (gec, coverage due to the disparity in popu- 7 June 2015). lation between India (1.2 billion) and Other prominent members of the Guam (170,000) (Macquire 2015). community who passed away during This was the first time that Guam has the year under review were former secured any foothold in World Cup Speaker Franklin Joseph Arceo Qui- qualifying matches. In 2000, the last tugua, former Senator Jesus “Jess” time Guam participated in the World Q Torres, and former Yona Mayor Cup qualifying heats, it lost to Iran Vicente “Ben” Bernardo. Guam’s (19-0) and Tajikistan (16-0) (Times of community also lost Anthony “Tony” India 2015). Ramirez, former administrator and As a prelude to Guam’s hosting curator of the Guam Museum and of the 12th Festival of Pacific Arts advocate for Guam’s culture and his- (FestPac) in 2016, the 28th Annual tory, as well as Joaquin Flores Lujan, Guam Micronesia Island Fair was held known as “Tun Jack,” a traditional in June as a “springboard” for FestPac Chamorro blacksmith. In 1996, Tun (gvb, 30 April 2015). In addition to Jack was one of the first cultural performances by Chamorro dancers artisans to be recognized by the Guam and artisans, artists from Palau, Yap, Council on the Arts and Humani- Kosrae, and the Marshall Islands also ties as a Master of Chamorro culture participated in the three-day event and has been the only person from held at Ypao Beach Park (pdn, 11 June the Western Pacific region to win a 2015). At the 2016 FestPac, Guam National Heritage Award Fellowship will host an estimated 2,500 art- (J Balbas, pers comm, 17 Aug 2015; ists from twenty-seven Pacific Island mv, 24 Jan 2015; 33rd Guam Legisla- nations and territories and draw some ture website). 10,000 others from around the world In the field of sports, milestones (Office of Governor, 16 Feb 2015). were reached as Guam topped the The issue of historic buildings in medal count at the 2014 Micronesian the capitol of Hagåtña was a source Games. Held in July in Pohnpei, the of controversy as the Legislature event involved ten Micronesian states, acted to approve a Calvo admin- territories, and independent nations istration proposal to demolish the competing over ten days. Guam scored vacant Manuel F L Guerrero building. 190 the contemporary pacific • 28:1 (2016)

Opponents of the move called for the accounts and unbudgeted expenses building’s renovation and preserva- such as retroactive pay raises and tion, citing its historic significance reserves for Guam Memorial Hospital as well as its economic development (pdn, 6 May 2015). The Legislature’s potential (see, eg, Cruz 2015). From appropriations chair, Vice Speaker World War II until relatively recently, Benjamin Cruz, stated that he was the building housed several govern- not satisfied with the administra- ment functions. In particular, it served tion’s explanation and wanted to see as the seat for Guam’s first appointed the final audit report for 2014 (pdn, Chamorro governor, the first locally 6 May 2015). The issue of the Gov- elected governor, and the first cohort Guam deficit promised to be a central of locals serving as heads of govern- concern as the Legislature takes up ment agencies in the 1960s and 1970s. next year’s budget during the summer In the 1980s, the governor’s office months of 2015. was relocated to Adelup by Governor Plans moved forward for the widely Ricardo Bordallo, and most govern- anticipated and debated Guam and ment agencies housed in the building Northern Mariana Islands military moved out over time. Proponents of buildup. The centerpiece of the the demolition proposal cited the high buildup is the relocation of US Marine cost and limited utility of renovat- units from Okinawa to Guam, for ing the building (Stars and Stripes, which the Japanese Government has 6 March 2015). On the positive side, provided $3.1 billion. The remainder the Historic Preservation Review of the funding for the move, estimated Board placed the Old Court Building at more than $8 billion, is to come of Hagåtña, presently serving as the from the US Department of Defense Guam Judicial Annex, on the Guam (dod). US Senator John McCain and Register of Historic Places, along with others in the US Congress have been the Chagui'an Massacre Site in Yigo, skeptical about dod spending plans at which forty-five Chamorros had and acted to freeze funding pending been brutally beheaded during World completion of a master plan, which War II. Another significant act was was submitted to Congress in August Guam’s passing of Public Law 33-56, 2014. On Guam, opponents of the which proclaimed 28 June as War buildup have questioned the purported Survivor Remembrance Day to honor economic gains, the infrastructure survivors of the harsh Japanese occu- costs, and the damaging environmen- pation of Guam during World War II tal impact related to dod plans, as (mv, 27 June 2015). well as the disturbance of ancestral Concerns were raised in May 2015 sites by proposed military activities. when a $65.3 million deficit was Bringing such concerns front and cen- reported for the Government of Guam ter were recent instances such as the (GovGuam) in fiscal year 2014. Calvo beaching of three whales in southern administration officials explained that Guam during US Navy sonar testing this was only a paper deficit and not (kuam, 27 March 2015). a cash deficit, resulting from large Guam’s community now awaits the amounts of funds retained in trust issuance of the dod Record of Deci- political reviews • micronesia 191 sion, which will detail its final plans est, the development of the island’s for the buildup (Stars and Stripes, National Wildlife Refuge units, and 3 Nov 2014). Although it had been more. Another salient issue is that expected in March 2015, as of this there appear to be two divergent per- writing, the Department of Defense ceptions of Guam in play: indigenous- has delayed issuance of the Record local and military. As expressed by of Decision to the summer of 2015 one community member, “Guam is (pnc, 18 June 2015). Keeping track our home, not a strategic outpost”— of the intensive militarization activity, the latter of which appears to many finding the appropriate dod informa- to be the way the military view the tional websites, and wading through Marianas (pdn, 2 Jan 2015). the environmental impact assessment One outcome of the above con documents is an immense task for the troversies has been strengthening community. Adding to this burden, solidarity in the Marianas archipelago, reviewers say that such documents crossing modern political divides that are “woefully inadequate,” “do not result from the historic colonial divvy- conform with the ‘basic principles’ of ing up of homeland islands. Members protective federal legislative require- of both Guam and Northern Mari- ments such as the National Environ- ana Islands communities have been mental Policy Act,” and “preclud[e] signing petitions, publishing videos, intelligent review” (Saipan Tribune, writing op-ed pieces, and participat- 2 June 2015). Some community senti- ing in forums such as the University of ments expressed over the last year Hawai‘i’s Asian-Pacific Law & Policy mirror these findings. For example, Journal forum “Bombs in Paradise: a sign held by protestors at a public A Legal, Social, and Political Discus- meeting stated that, regarding the sion of Militarization in the Pacific,” buildup, there was a “shortage of at which attorney Julian Aguon, legal detailed information and a lack of counsel to the Guam Legislature, local involvement in decisions that served as the keynote speaker (see, will affect the island” (pdn, 2 Jan eg, Yanger 2015; Cabrera and others 2015). Island leaders, many in the 2015; Hofschneider 2015). community, and even outside observ- While the military buildup plans ers have expressed feeling that each proceeded, Guam posted record- of these deficiencies is an intentional breaking numbers for tourist arrivals strategy to confuse, overwhelm, and in 2014. In October, it was announced wear down the community to the that overall arrivals for the 1 October point of minimizing their ability to 2013–30 September 2014 fiscal year provide meaningful input. For several reached 1,341,054 visitors (Office years now, public comments have of the Governor, 10 Oct 2014). But continuously been sought or have been concerns were raised at the Univer- gathered simultaneously regarding sity of Guam’s 6th Regional Island different militarization issues, such as Sustainability Conference about plans access to traditional medicinal plants to increase tourism to two million visi- and ancestral and historical sites, the tors by 2020 (Dumat-ol Daleno 2015). bulldozing of pristine limestone for- In the months leading up to the US 192 the contemporary pacific • 28:1 (2016)

Supreme Court 5-4 decision in favor c1ynp/E11E8ED4-69BD-4875-8E91 of same-sex marriage, the issue was -0F87B34E0529 [accessed 18 July 2015] argued publicly and in court on Guam Dumat-ol Daleno, Gaynor. 2015. Guam’s (pdn, 27 June 2015). In April 2015, Tourism Plan Raises Concerns. The Wash- after a same-sex couple unsuccess- ington Times, 25 April. http://www fully attempted to acquire a mar- .washingtontimes.com/news/2015/apr/ riage license on the island, Attorney 25/guams-tourism-plan-raises-concerns/ General Elizabeth Barrett-Anderson ?page=all [accessed 20 June 2015] directed Public Health officials to gec, Guam Election Commission website. issue the license, but they refused Hagåtña. gec.gov.guam with the backing of Governor Calvo. Guam National Olympic Committee web- The matter was taken to the local US site. 2014. Team Guam Tops Medal Tally. District Court, which ruled in favor 30 July. http://www.foxsportspulse.com/ of issuing marriage licenses to same- assoc_page.cgi?client=1-3846-0-0-0&sID sex couples, making Guam the first =333031&&news_task=DETAIL US territory with legal gay marriage. &articleID=30790404 [accessed 20 June This ruling came three weeks prior to 2015] the US Supreme Court overturning gvb, Guam Visitors Bureau website. 2015. bans on same-sex marriage nationwide 2015 Guam Micronesia Island Fair Bridges (Bordallo 2015). “Journey to FestPac.” News release, 30 michael bevacqua, April. https://www.guamvisitorsbureau .com/news/news-releases/2015-guam kelly g marsh, and -micronesia-island-fair-bridges-journey tyrone j taitano -to-festpac [accessed 18 July 2015] Hofschneider, Anita. 2015. uh Summit to References Explore Impact of Militarization on Pacific Islands. Honolulu Civil Beat, 5 April. 33rd Guam Legislature website. Hagåtña. http://www.civilbeat.com/2015/04/uh http://www.guamlegislature.com/ -summit-to-explore-impact-of Bordallo, Grace Garces. 2015. Guam -militarization-on-pacific-islands/ Becomes First US Territory to Recognize [accessed 18 July 2015] Gay Marriage after Judge’s Decision. Huffington Post. New York City. US News, 5 June. http://www.usnews http://www.huffingtonpost.com/ .com/news/us/articles/2015/06/05/guam -becomes-first-us-territory-to-recognize kuam, kuam.com: Guam’s News Net- -gay-marriage [accessed 20 June 2015] work. Hagåtña. http://www.kuam.com/ Cabrera, Genevieve S, Cinta M Kaipat, Last Week Tonight with John Oliver: Kelly G Marsh-Taitano, and Rick Perez. U.S. Territories (hbo). 2015. YouTube, 2015. Facts You Need to Know about 8 March. https://www.youtube.com/ Gathering Community Input in Guam and watch?v=CesHr99ezWE [accessed the NMI. Marianas Variety, 16 June. 27 July 2015] Cruz, Senator Benjamin [“BJ”] J F. 2015. Macguire, Eoghan. 2015. World Cup Cruz Opposes Destruction of Historic 2018: Tiny Pacific Island Beats Nation of Building. 3 March. http://www 1.2 Billion. cnn, 16 June. http://edition .senatorbjcruz.com/#!Cruz-Opposes .cnn.com/2015/06/16/football/world-cup -Destruction-of-Historic-Building/ -2018-guam-india/ [accessed 2 June 2015] political reviews • micronesia 193

Marsh, Kelly G, and Tyrone J Taitano. with macro-level political, economic, 2014. Micronesia in Review: Issues and and environmental concerns. These Events, 1 July 2012 to 30 June 2013: tensions were perhaps most appar- Guam. The Contemporary Pacific ent in the Marshall Islands’ ongoing 26:170–177. lawsuit against the United States and mv, Marianas Variety, Guam edition. eight other nuclear-armed nations, top Weekdays. Harmon, Guam. leaders’ vocal participation in global http://mvguam.com climate-change discussions, several Office of Governor Eddie Baza Calvo controversial government expenditures website. http://governor.guam.gov/ and continuing financial mismanage- ment, less-than-desirable rankings pdn, Pacific Daily News. Hagåtña, Guam. http://www.guampdn.com/ on several regional and international reports, and increasing outmigration. pnc, Pacific News Center, Sorenson That said, government leaders, non- Media Group. Hagåtña, Guam. governmental organizations, educa- http://www.pacificnewscenter.com/ tional institutions, and private citizens Saipan Tribune. Daily. Garapan, Saipan. made noteworthy efforts to address http://www.saipantribune.com/ these issues through governmental and Stars and Stripes. Daily. Washington dc. institutional policy, direct action, and http://www.stripes.com/ participation in local, regional, and The Times of India. 2015. fifa World Cup international organizations. Mean- Qualifiers: Guam Claim Historic Win. while, the run-up to the 2015 election 12 June http://timesofindia.indiatimes kicked off in September 2014, with .com/sports/football/top-stories/Fifa-World local and national elections scheduled -Cup-qualifiers-Guam-claim-historic-win/ for the third Monday in November— articleshow/47638723.cms [accessed recently designated a national holiday 20 June 2015] by the Nitijeḷā (Parliament). As of this Yanger, Tasi. 2015. Guahan in Solidarity writing, it remains to be seen whom with Tinian and Pagan. Video created by the people of the Marshall Islands will Academy of Our Lady of Guam’s History elect to steer their country’s course and Culture of Guahan Class of 2015. over the next four years. YouTube, 6 May. https://www.youtube With the 2015 election looming, .com/watch?v=bL5yDV0IZtQ [accessed a few key issues consistently made 28 June 2015] headlines during the period under review. Among these were two law- suits filed in April 2014—one against the United States and eight other Marshall Islands nuclear-armed nations (China, France, Several issues took center stage in India, Israel, North Korea, Pakistan, the Republic of the Marshall Islands Russia, and the United Kingdom) at (RMI) from July 2014 to June 2015, the International Court of Justice (icj) revealing ongoing tensions between in The Hague and the other against the government’s duty to attend to the United States in a federal district the everyday needs of the Marshallese court in San Francisco (Radio Aus- people and its necessary engagement tralia 2014; Lawyers Committee on