No. ______ In the Supreme Court of the United States ________________ GUAM, GUAM ELECTION COMMISSION, and MICHAEL J. PEREZ, ALICE M. TAIJERON, G. PATRICK CIVILLE, JOSEPH P. MAFNAS, JOAQUIN P. PEREZ, GERARD C. CRISOSTOMO, and ANTONIA GUMATAOTAO, in Their Official Capacities as Members of the Guam Election Commission, Petitioners, v. ARNOLD DAVIS, on behalf of himself and all others similarly situated, Respondent. ________________ On Petition for Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit ________________ PETITION FOR WRIT OF CERTIORARI ________________ PHILIP M. COOPER MICHAEL F. WILLIAMS, P.C. KIRKLAND & ELLIS LLP Counsel of Record 300 North LaSalle LAUREN N. BEEBE Chicago, IL 60654 ELIZABETH HEDGES* THOMAS S. VASELIOU† KIRKLAND & ELLIS LLP 1301 Pennsylvania Ave., NW Washington, DC 20004 (202) 389-5000
[email protected] Counsel for Petitioners *†Additional Counsel Information Listed on Inside Cover December 26, 2019 *Admitted only in Virginia and practice is supervised by principals of the Firm. †Admitted only in Texas and practice is supervised by principals of the Firm. QUESTION PRESENTED Shortly after the end of World War II, Congress extended citizenship to certain inhabitants of Guam through the 1950 Organic Act of Guam, 48 U.S.C. § 1421 et seq. Fifty years later, the government of Guam decided to invite that same class of people to express their views on the island’s future political relationship with the United States. Under the 2000 Plebiscite Law, “native inhabitants of Guam”— defined as “those persons who became U.S. Citizens by virtue of the authority and enactment of the 1950 Guam Organic Act and descendants of those persons”—can indicate their preference for one of three “political status options”: (1) “Independence,” (2) “Free Association with the United States of America,” or (3) “Statehood.” 1 Guam Code Ann.