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5 Guam opinions name it 1 courts 2024–2026 5 in the last five years
The cases below were cited by Guam courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
United States v. Robert D'Amoregreen1 sentence2026The trial court’s inquiry into the conflict was inadequate [45] Crisostomo argues “[t]he trial court limited its review to discussion with trial counsel and the government about whether [P.C.] would be called to testify and if there was information obtained from previous representation that would affect ability [sic] to represent Crisostomo.” Appellant’s Br. at 18. [46] “Before the [trial] court can engage in a measured exercise of discretion, it must conduct an inquiry adequate to create a ‘sufficient basis for reaching an informed decision.’” United States v. D’Amore, 56 F.3d 1202, 1205 (9th | 1 | 1 |
Willie Enoch v. Richard Gramley, Warden, Pontiac Correctional Centergreen1 sentence2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 | 1 | 1 |
People of Guam v. Michael Anthony Libbygreen1 sentence2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 | 1 | 1 |
United States v. Rupert Earl McClendon United States of America v. Bernest Collinsgreen1 sentence2026The trial court’s inquiry into the conflict was inadequate [45] Crisostomo argues “[t]he trial court limited its review to discussion with trial counsel and the government about whether [P.C.] would be called to testify and if there was information obtained from previous representation that would affect ability [sic] to represent Crisostomo.” Appellant’s Br. at 18. [46] “Before the [trial] court can engage in a measured exercise of discretion, it must conduct an inquiry adequate to create a ‘sufficient basis for reaching an informed decision.’” United States v. D’Amore, 56 F.3d 1202, 1205 (9th | 1 | 1 |
Guenter Mannhalt v. Amos E. Reedgreen2 sentences2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 | 1 | 1 |
United States v. Trung Tran Nguyengreen1 sentence2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 | 1 | 1 |
Kevin T. Hall v. United Statesgreen2 sentences2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 | 1 | 1 |
United States v. Cortrayer Zonegreen2 sentences2026We have adopted the Ninth Circuit standard that “allows appeals for all ‘colorable’ double jeopardy challenges, meaning claims that have ‘some possible validity.’” Id. (quoting United States v. Zone, 403 F.3d 1101, 1104 (9th Cir. 2005) (per curiam)). 2026We have adopted the Ninth Circuit standard that “allows appeals for all ‘colorable’ double jeopardy challenges, meaning claims that have ‘some possible validity.’” Id. (quoting United States v. Zone, 403 F.3d 1101, 1104 (9th Cir. 2005) (per curiam)). | 1 | 1 |
United States v. Paul Kent Casselgreen1 sentence2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 | 1 | 1 |
cluster 10876646green1 sentence2026See Libby, 2021 Guam 27 ¶ 26 (“In reviewing the denial of a request or motion for new counsel, we consider three factors . . . .” (quoting United States v. Cassel, 408 F.3d 622, 637 (9th Cir. 2005)) (citing Nguyen, 262 F.3d at 1004 ). [44] While the People rely on the factors set out by the Seventh Circuit for cases of successive representation, Appellee’s Br. at 4 (citing Hall v. United States, 371 F.3d 969, 973 (7th Cir. 2004)), the Seventh Circuit cites the Ninth Circuit for these factors, see Hall, 371 F.3d at 973 (applying standard Seventh Circuit adopted from Mannhalt v. Reed, 847 F.2d 5 | 1 | 1 |
United States v. Prentiss Anthony Crumblegreen2 sentences2025The trial court correctly articulated the legal standard adopted in the Ninth Circuit and several other jurisdictions, e.g., United States v. Crumble, 878 F.3d 656, 659 (8th Cir. 2018); United States v. Basinski, 226 F.3d 829, 837 (7th Cir. 2000); State v. Prior, 973 N.W.2d 726, 744 (Neb. 2025The trial court correctly articulated the legal standard adopted in the Ninth Circuit and several other jurisdictions, e.g., United States v. Crumble, 878 F.3d 656, 659 (8th Cir. 2018); United States v. Basinski, 226 F.3d 829, 837 (7th Cir. 2000); State v. Prior, 973 N.W.2d 726, 744 (Neb. | 1 | 1 |
United States v. Volodymyr Kvashukgreen2 sentences2025The court cited the Ninth Circuit’s standard, under which “juror bias will be presumed only in the extreme situation where the relationship between a prospective juror and some aspect of the litigation is such that it is highly unlikely that the average person could remain impartial in their deliberations under the circumstances.” Id. (citing United States v. Kvashuk, 29 F.4th 1077, 1092 (9th Cir. 2022)). 2025The trial court concluded that “the relationship between the juror and the issues of this case [was] too tenuous to meet the ‘extreme situation’ standard established by the Ninth Circuit.” Id. | 1 | 1 |
State v. Priorgreen2 sentences2025The trial court correctly articulated the legal standard adopted in the Ninth Circuit and several other jurisdictions, e.g., United States v. Crumble, 878 F.3d 656, 659 (8th Cir. 2018); United States v. Basinski, 226 F.3d 829, 837 (7th Cir. 2000); State v. Prior, 973 N.W.2d 726, 744 (Neb. 2025The trial court correctly articulated the legal standard adopted in the Ninth Circuit and several other jurisdictions, e.g., United States v. Crumble, 878 F.3d 656, 659 (8th Cir. 2018); United States v. Basinski, 226 F.3d 829, 837 (7th Cir. 2000); State v. Prior, 973 N.W.2d 726, 744 (Neb. | 1 | 1 |
United States v. Joseph N. Basinskigreen2 sentences2025The trial court correctly articulated the legal standard adopted in the Ninth Circuit and several other jurisdictions, e.g., United States v. Crumble, 878 F.3d 656, 659 (8th Cir. 2018); United States v. Basinski, 226 F.3d 829, 837 (7th Cir. 2000); State v. Prior, 973 N.W.2d 726, 744 (Neb. 2025The trial court correctly articulated the legal standard adopted in the Ninth Circuit and several other jurisdictions, e.g., United States v. Crumble, 878 F.3d 656, 659 (8th Cir. 2018); United States v. Basinski, 226 F.3d 829, 837 (7th Cir. 2000); State v. Prior, 973 N.W.2d 726, 744 (Neb. | 1 | 1 |
cluster 724041green1 sentence2024See Collicott, 92 F.3d at 979 ; People v. Hall, 2004 Guam 12 ¶ 36. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Guam. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
United States v. Garrett
green
1 sentence2026The trial court’s inquiry into the conflict was inadequate [45] Crisostomo argues “[t]he trial court limited its review to discussion with trial counsel and the government about whether [P.C.] would be called to testify and if there was information obtained from previous representation that would affect ability [sic] to represent Crisostomo.” Appellant’s Br. at 18. [46] “Before the [trial] court can engage in a measured exercise of discretion, it must conduct an inquiry adequate to create a ‘sufficient basis for reaching an informed decision.’” United States v. D’Amore, 56 F.3d 1202, 1205 (9th | 1 | 2026–2026 |
People of Guam v. Louis Anthony Vargas
green
2 sentences2026The Ninth People v. Vargas, 2026 Guam 1, Opinion Page 6 of 23 Circuit has held that a claim is colorable if it is an issue of first impression. 2026The Ninth People v. Vargas, 2026 Guam 1, Opinion Page 6 of 23 Circuit has held that a claim is colorable if it is an issue of first impression. | 1 | 2026–2026 |
United States v. Eric Gonzalez
green
1 sentence2025The court cited the Ninth Circuit’s standard, under which “juror bias will be presumed only in the extreme situation where the relationship between a prospective juror and some aspect of the litigation is such that it is highly unlikely that the average person could remain impartial in their deliberations under the circumstances.” Id. (citing United States v. Kvashuk, 29 F.4th 1077, 1092 (9th Cir. 2022)). | 1 | 2025–2025 |
People of Guam v. Joseph Quichocho Taimanglo II (aka Joseph Quichocho Taimanglo; aka Baby Joe; aka Joseph Quintanilla Taimanglo II)
green
2 sentences2025The People make no attempt to show the trial court committed clear error when it found “it People v. Taimanglo, 2025 Guam 7 , Opinion Page 14 of 20 relying on the Ninth Circuit standard was an error. 2025The People make no attempt to show the trial court committed clear error when it found “it People v. Taimanglo, 2025 Guam 7 , Opinion Page 14 of 20 relying on the Ninth Circuit standard was an error. | 1 | 2025–2025 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.