48 U.S.C. § 1801

Approval of Covenant to Establish a Commonwealth of the Northern Mariana Islands

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The Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America, the text of which is as follows, is hereby approved.

Notes of Decisions
Cited in 54 cases (9 in the last 5 years), 1994–2026 · leading case: United States v. Vaello Madero, 596 U.S. 159 (2022).
United States v. Vaello Madero, 596 U.S. 159 (2022). · cites it 2× “Note following 48 U. S. C. §1801 ; 90 Stat. 268 . But residents of Puerto Rico are not eligible for Supple- mental Security Income.”
Armstrong v. Commonwealth of N. Mariana Islands, 576 F.3d 950 (9th Cir. 2009). · cites it 4× “Armstrong also argues that the district court had original jurisdiction over her claims pursuant to a provision in the Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America (“Covenant”), reprinted in 48 U.S.C. §…”
Xianli Zhang v. United States, 640 F.3d 1358 (Fed. Cir. 2011). · cites it 2× “263 (codified as amended at 48 U.S.C. § 1801 note (2006)) (“Covenant”).”
Commonwealth of the N. Mariana Islands v. United States, 279 F.3d 1070 (9th Cir. 2002). · cites it 3× “We conclude that, although the CNMI is not a “State” under the Quiet Title Act, the Covenant to Establish a Commonwealth of the Northern Mariana Islands, 48 U.S.C. § 1801 and notes following, requires that we treat the CNMI as if it were a State for the purposes of the Quiet…”
Saipan Stevedore Co. Inc. v. Dir., Off. of Workers' Comp. Programs Helal Uddin, 133 F.3d 717 (9th Cir. 1998). · cites it 3× “The Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America (“Covenant”), ratified by Congress by joint resolution, 7 established the Commonwealth as an unincorporated territory of the United States.”
United States v. Chang Da Liu, 538 F.3d 1078 (9th Cir. 2008). “48 U.S.C. § 1801 . The Covenant became law in 1976 and became completely effective in 1986.”
Enrique Agulto SANTOS; & Ignacia A. Santos, Plaintiffs-Appellees, v. NANSAY MICRONESIA, INC., Defendant-Appellant, 76 F.3d 299 (9th Cir. 1996). · cites it 3× “JURISDICTION The Santoses argue that this court lacks jurisdiction over federal due process issues because they were not properly raised or passed upon by the CNMI Supreme Court.”
Zhang v. United States, 89 Fed. Cl. 263 (Fed. Cl. 2009). · cites it 3× “263 (codified as amended at 48 U.S.C. § 1801 note (2006)) (the “Covenant”), normalized the relationship between the United States and the Northern Mariana Islands.”
United States v. Vaello-Madero, 956 F.3d 12 (1st Cir. 2020). “263, 268 (1976) (codified as 48 U.S.C. § 1801 ); see also 20 C.F.R. § 416.”
Fang Lin Ai v. United States, 809 F.3d 503 (9th Cir. 2015). “263 (1976), and is codified as a note following 48 U.S.C. § 1801 . Several of our opinions have detailed the history of the Covenant and U.”
Gary Ramsey v. Esther Muna, 849 F.3d 858 (9th Cir. 2017). “See 48 U.S.C. § 1801 (setting out the text of the Covenant).”
United States v. Lara, 124 S. Ct. 1628 (2004). “in political union with and under the sovereignty of the United States”); the Philippines—22 U.”
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